If we have not met, here are my credentials: I have been involved with disaster work for nearly 20 years beginning with the recovery of New Orleans after Hurricane Katrina and the levee failure. I worked major disasters from BP to Joplin as part of the disaster nonprofit sector. I then went on to earn my master’s and PhD in emergency management. I have spent the last decade researching the U.S. emergency management system, teaching emergency management including a course on Disaster Policy, and providing analysis of the emergency management system to the public via major news outlets.
Every four (or eight) years the U.S. emergency management system undergoes changes as a new Presidential administration takes power. Emergency management and the emergencies, disasters, and catastrophes for which we seek to mitigate, prepare for, respond to, and recover from operate within, and are influenced by, our political context. Therefore, it is not possible to understand, nor do effective emergency management, without understanding that political context. This context affects everything in emergency management, from the type and size of events we need to manage, to what type of search and rescue trainings are offered, to whether you can rebuild your house after a fire.
It is a fundamental truth that disasters are a product of political choice. Risk creation is political. Risk reduction is political. Emergency management is political. Disaster science is political. Disasters are political and pretending they are not only helps to facilitate further harm.
As a product of politics, the approach to emergency management is ever changing. In fact, the term “emergency management” dates back only to the late 1970s. It first emerged as a jumbled function of disaster relief, and then in the late 1940s emerged as a more formally coordinated Civil Defense. With each iteration, the mission of the field has been expanded and clarified. These changes have been driven by the evolving nature of the hazards we face and the social expectations of the public and the politicians who have led the country. For example, the disaster relief programs included within the New Deal were demanded by the electorate in their outright rejection of Hoover’s failure to use the federal government to manage crises.
And so today, we once again face a time of likely change for the U.S. emergency management system. I do not pretend to know exactly what the future holds, but in adhering to one of the core ethos of the field of emergency management, we need to assess our risk to know what we need to do to mitigate and prepare for our new political context. To help guide what I hope becomes a robust policy discussion about the future of emergency management practice, policy, and research, I have worked line by line through the conservative policy agenda. As the soon-to-be ruling party, it is critical to understand how they think about emergency management and what laws and policies they may enact.
Project 2025
The primary way I will explore this is through an analysis of Project 2025. You can read a broad explainer here but effectively it is the conservative manifesto, or as they call it the “governing agenda” for the Trump Administration. The centerpiece is a 900-page document which is the culmination of conservative philosophy and plans for the incoming administration.
At various points during the campaign, Trump tried to distance himself from Project 2025. Yet, this is a document that I believe we have every reason to take both seriously and literally. Many of Project 2025’s leading architects worked for the previous Trump administration and many more of them are already involved in the transition team and will take up prominent positions within the administration. JD Vance wrote the preface to Kevin Robert’s book (the primary author of Project 2025) and Trump has selected Russell Vought to run the critical Office of Management and Budget.
Even if the Trump administration does not implement Project 2025 in its entirety, this document contains the most comprehensive conservative recommendations for changes to emergency management policy. It is important to also be aware of the America First Agenda and Agenda 47. I will not go through either here because they are not as robust. There is no comparable document produced by liberal thinkers (or thinkers of any other political leaning, for that matter).
Project 2025 was organized by the Heritage Foundation, but it represents what is effectively the consensus conservative policy viewpoint of dozens of organizations and many more individual contributors. Amy Westervelt has researched the conservative organizations involved and produced a reference spreadsheet that you can review here. This network of organizations represents a powerful lobby that will undoubtedly advocate for the implementation of their ideas not only to the Trump administration but to members of Congress as well.
In the last Trump administration, many policy ideas from the Heritage Foundation were implemented. You may remember that they were the ones to write “Mandate for Leadership: Policy Management in a Conservative Administration” which formed the foundation of the Reagan administration’s policy agenda. They have done this before and this time they are more extreme and more organized.
Project 2025 refers not just to the 900-page policy agenda called “Mandate for Leadership: The Conservative Promise” but also to a four-pillar strategy. The policy agenda is one pillar, the others include a database of appointees willing to implement the agenda, a Presidential Administration Academy to teach appointees about basic government functions, and agency teams who are ready to implement the agenda on the “utterance of ‘so help me God’”. From the outside, it looks like they have built the infrastructure to implement the agenda wholesale.
It is impossible to know at this point which parts – if all or any – will be implemented. A written policy agenda can manifest in vastly different ways depending on how it is operationalized in policy and practice. Who within the administration is responsible for the Federal Emergency Management Agency (FEMA) will matter a great deal. What Congress agrees to will matter. The actual legal and political authority granted to individuals like Elon Musk and Vivek Ramaswamy will matter.
There are two other big wildcards. If we learned one thing from the first Trump administration, it is that both the President and the people he surrounds himself with are erratic decision-makers. It is not always possible to predict what Trump will fixate on – sometimes it is what he says he will like the wall on the southern border, but other times new fixations pop up seemingly out of nowhere. For example, the Hurricane Map Sharpie-Gate took me by surprise. In the post-Helene context has he soured on FEMA? Will he think he can make FEMA better? How would he approach doing so? Or will he not think of FEMA at all?
Our second wildcard is what disasters (broadly defined) will befall us in the coming months and years. H5N1 is bubbling up, other disasters will happen, and the possibility of expanding wars looms as global tensions increase. How, when, and where these events manifest may redirect the plans (for better or worse) for emergency management policy.
The ways in which Project 2025 could affect emergency management are immense. To help wrap our heads around possible changes I have separated the analysis into three categories.
1) Impacts to the Federal Emergency Management Agency (FEMA)
2) Impacts to the broader federal emergency management system (i.e., other federal agencies which are formally involved with emergency management)
3) Impacts to our overall national disaster risk
The rest of this post will focus on problem #1: the impacts of Project 2025 to FEMA. It is important to understand that these changes will trickle down to state and local government, the private sector, and nonprofits.
We must be careful to avoid normalcy bias but it is also not my intention to fearmonger or catastrophize. Rather I am looking to help us all understand the potential changes and their implications. This document is poorly written and suffers from a lack of understanding of emergency management structure and policy. As a result, it approaches being nonsensical at times and there is as much subtext as there are half-baked ideas. There are several places where assumptions do need to be made and gaps I have needed to fill to even be able to explain to the casual reader what is being suggested. I highlight where I have made assumptions and why for the sake of transparency. Still, I am taking what is written literally.
Last caveat: to my knowledge, this is the most in-depth analysis of the proposed policy changes to FEMA in Project 2025. Even so, other emergency management policy experts will note that the intricacies of these proposed changes are much more nuanced than explained here. I have written this for a general audience and therefore prioritized what is most urgent for the average person to know about these changes.
Proposed Changes to FEMA
The section on FEMA is located within a long chapter on the Department of Homeland Security (DHS) but is itself only two pages in length. It consists of three sections: needed reforms, budget issues, and personnel.
The author of the DHS chapter, including the FEMA section, is Ken Cuccinelli, the former deputy secretary of DHS (2019-2021). You may remember him from his days as Virginia’s Attorney General where he led a harassment campaign against Dr. Michael Mann and his climate research. Mann eventually won in a ruling from the Virginia Supreme Court that unpublished research should not be subjected to FOIA requests. The Union of Concerned Scientists followed the situation closely. This is good context to keep in mind as you read his proposed FEMA changes as they very much align with his anti-science and climate denialist history.
Incidentally, I have been unable to find anything in his background that qualifies him to propose emergency management policy. He is not by any measure an emergency management expert. It is noted that others contributed to the overall DHS chapter but those are not separated from the book’s overall contributors. Without doing a full background search of the 250 contributors listed I do not see any names I recognize as being emergency management experts. So, it is unclear if any contributors have emergency management expertise. Based on how the section is written my guess is they do not. I will be attributing the policy proposals in the DHS chapter to Cuccinelli as the lead author.
The Problem with FEMA
The FEMA sub-section begins by laying out what Cuccinelli views as the problems with FEMA:
“FEMA is the lead federal agency in preparing for and responding to disasters, but it is overtasked, overcompensates for the lack of state and local preparedness and response, and is regularly in deep debt. After passage of the 1988 Stafford Act, the number of declared federal disasters rose dramatically as most disaster costs were shifted from states and local governments to the federal government. In addition, state-friendly FEMA regulations, such as a “per capita indicator,” failed to maintain the pace of inflation and made it easy to meet disaster declaration thresholds. This combination has left FEMA unprepared in both readiness and funding for the truly catastrophic disasters in which its services are most needed. Reform of FEMA requires a greater emphasis on federalism and state and local preparedness, leaving FEMA to focus on large, widespread disasters.”
In short: Cuccinelli believes FEMA is doing too much and spending too much money. It is unclear what dollar amount he would prefer FEMA spend nor is it clear how he intends to decide which part of the emergency management mission is the responsibility of the federal government versus that of state and local. He says that FEMA should only be involved in “truly catastrophic disasters” and “large widespread disasters”, but he does not define these terms. The way these terms are ultimately defined would be the single biggest factor in how extreme these changes may be.
It is well understood in emergency management that state and local governments should do more to prepare for both response and recovery. Yet, Cuccinelli does not identify the reasons why state and local agencies are not doing more to prepare (e.g., lack of capacity, lack of knowledge, lack of priority, lack of authority). As a result, the policy changes he suggests later in the FEMA sub-section do not actually address the problem. In fact, the proposed policy changes would in all likelihood make state and local preparedness even more difficult to accomplish and result in less overall state and local preparedness.
You do not need to take my word on this because FEMA is currently funding a study to look at the capacity of state and local emergency management – an issue which is at the core of the state and local preparedness problem. The results will be published in a few months and should provide us with a more nuanced understanding of this national problem. The results of this study will provide an empirical basis on which policy proposals can emerge to address the state and local preparedness problem. (But spoiler: the solution will not be taking away the already limited resources that are contributing to capacity building as suggested here).
The number of Presidential Disaster Declarations and FEMA’s spending on disasters have increased. However, Cuccinelli fails to holistically contextualize these changes. He identifies FEMA’s “per capita indicator” to be a key reason for the increased federal spending on disasters (I will explain what that means in detail below). Federal policy has evolved over time as our collective understanding of what constitutes a disaster has changed but there is also a much broader range of explanatory factors well established in the disaster literature (e.g., unchecked development in high-risk areas, decaying infrastructure, population movement, climate change). When risk increases without mitigation and preparedness efforts keeping pace, then there will be more disasters and the cost of those disasters will increase. (More on this in the third blog post of this series.)
Cuccinelli claims costs have shifted from state and local governments to the federal government. He does not provide evidence for this claim. As someone who has spent years sifting through emergency management budgets, I do not think this is true. State and local governments have never spent much money on emergency management. To find a time in American history when the federal government was not directly contributing to disaster costs regularly, you have to go back pre-New Deal. The early 1900s were surely not a time when state and local governments were doing effective emergency management. So, while we do know federal spending on disasters has increased, we do not have the financial data to be able to say that state and local disaster spending has decreased. This is important because what is being suggested here is not a return to an old way of doing emergency management where state and locals pay for disasters themselves, but rather something new and untested.
Cutting FEMA’s Spending
Cuccinelli next suggests how FEMA’s spending should be slashed:
“Under the Stafford Act, FEMA has the authority to adjust the per capita indicator for damages, which creates a threshold under which states and localities are not eligible for public assistance. FEMA should raise the threshold because the per capita indicator has not kept pace with inflation, and this over time has effectively lowered the threshold for public assistance and caused FEMA’s resources to be stretched perilously thin. Alternatively, applying a deductible could accomplish a similar outcome while also incentivizing states to take a more proactive role in their own preparedness and response capabilities. In addition, Congress should change the cost-share arrangement so that the federal government covers 25 percent of the costs for small disasters with the cost share reaching a maximum of 75 percent for truly catastrophic disasters.”
There are three distinct policy recommendations included here 1) raise the per capita indicator, 2) create a state deductible, and 3) reverse the federal cost-share.
Per Capita Indicator
The per capita indicator is a measure of the amount of damage a disaster has caused in each county and state. The indicator is a way to help FEMA determine if the event is significant enough to warrant federal involvement. If the cost of damage is above a particular amount per capita in a county/state then it is likely a declaration will be given.
In particular, the per capita indicator is used to determine the need for FEMA’s Public Assistance programs. Public Assistance is FEMA funding which supports the public costs of response and recovery (as opposed to funding that directly goes to individual survivors through the Individual Assistance programs). So, for example, Public Assistance can be used to reimburse state and local government (and nonprofits) for response-related costs like evacuation, sheltering, emergency food and water, search and rescue, and more. Public assistance can also cover recovery costs such as fixing roads, bridges, and other pieces of key infrastructure. It pays to rebuild schools and fire stations. To help reopen government offices. Fix sewage systems and rebuild parks.
Cuccinelli’s central claim is that the per capita indicator has not kept pace with inflation and therefore more disasters are being declared than should be declared. This is far too simplified. In 1986 when the per capita indicator began to be used the threshold was set at $1. Today that would be the equivalent of $2.88. Instead, today, we are sitting at $1.89. However, since 1999 both the state and county per capita indicators have kept pace with inflation.
Is it appropriate to continue using a standard set in 1986 that even at the time was not based on any data-driven metric of when a community is overwhelmed? Further, today’s disaster landscape is much different than 40 years ago. To say that our risk has changed, and more federal assistance is needed than was understood in the 1980s does not to me indicate a failure, but rather an evolution in our understanding of the importance of providing robust recovery resources in an effort to not only help more communities through recovery but also minimize secondary impacts and reduce vulnerability to future disasters. (Also, the entire approach to the relationship between inflation and the per capita indicator is problematic. If you want to get in the weeds you can read more here.)
It is difficult to know what exactly the implications of a change to the per capita indicator would be in practice for two reasons. First, Cuccinelli seems to think the per capita indicator is the deciding factor in determining declarations/ Public Assistance. It is certainly an important one, but it is not either legally or even necessarily in practice what makes this determination. FEMA also takes into account the extent of insurance coverage, hazard mitigation efforts, other recent disasters in the community, and the availability of other sources of government funding among other parts of a community’s situational context. In fact, the claim here that if a state or county does not reach the threshold then they are not eligible for Public Assistance is simply not true. The Stafford Act explicitly protects against using a specific formula to deny assistance (this is good – we want there to be flexibility for unique circumstances).
SEC. 320. LIMITATION ON USE OF SLIDING SCALES. No geographic area shall be precluded from receiving assistance under this Act solely by virtue of an arithmetic formula or sliding scale based on income or population. [42 U.S.C. 5163]
So, while it is common practice for this indicator to be used it is not the only factor. Further, although FEMA can alter the per capita indicator (as they now do annually based on the consumer price index), they do not decide whether a declaration is made and if Public Assistance will be given – this authority rests solely with the President. So, while Presidents typically take the advice of FEMA and are often interested in the extent of damage, the President’s decision is not bound by whether the per capita indicator threshold has been reached. Not to mention that reaching the threshold does not mean the President is required to make a declaration. It is just, as the name suggests, an indicator; it is not a law.
Putting this rather large issue aside, the other problem is that Cuccinelli does not say what the threshold for the per capita indicator should be. Does he think we should return to the original 1986 version of $1 ($2.88 today)? Or some other amount? How would that be decided? Do they intend to amend the Stafford Act and make the per capita indicator the deciding factor?
If so, that would dramatically reduce the authority of Presidents in disasters. Can we assume something similar will be done for Individual Assistance? If so, there would be effectively no power left in a President’s declaration authorities. This would signal the largest shift in disaster authority since the power for providing disaster relief was moved from Congress to primarily the Presidency.
Let us assume the per capita indicator is raised, and the President uses it as the sole determining factor for declaring a disaster and opening up Public Assistance. This would mean that overall fewer disasters would receive federal assistance. Fewer communities would receive funding for life-saving measures and rebuilding their public infrastructure. Which communities would be left out of receiving help depends on what is selected as the new per capita indicator. Regardless, this policy change would lower the immediate expenses of FEMA for response and recovery.
Presumably, this would then lead state and local governments to increase their disaster expenditures assuming they intend to meet the needs of the affected communities. First, I do not think that all state and local governments will even attempt to make up for this loss of federal funding. If, however, they want to try I think they will find it quite difficult. Some states may be able to find a way to cover at least some of these costs but not all will. The first obvious challenge would be for small states and less wealthy states. Their ability to come up with the funds for these events would require reworking state and local budgets which do not currently account for these potentially huge unforeseen expenses. This funding would presumably have to come either through an increase of state and local taxes or by reappropriating funding from something else.
Large states would also feel these impacts because although they have more money, they are likely to see a greater number of these small disasters. Because of the increase in hazard events across the country, it is also the case that many communities are experiencing multiple small events in quick succession. Texas, for example, has been the poster child for this in the southeastern part of the state. A county in Texas could easily see multiple storms in the span of a few years that cause extensive damage but still falls below the per capita threshold whereas if that same total amount of damage was caused by a single storm it would have easily crossed the threshold. (Incidentally, this is why FEMA does not currently only rely on the per capita indicator and instead also takes into account factors like previous disasters.)
Although every state and community would face being responsible for millions of dollars more in disaster response and recovery costs (in addition to what they are already paying), this change would without question disproportionately impact poor counties and states.
While I have you here, the actual problem with the per capita indicator is that it is measuring impacts, not needs. The same impacts for a wealthy community are being treated as equivalent to a poor community when in reality the wealthy community will have more resources to be able to address those impacts as compared to the poor community. FEMA has tried to mediate some of this through the inclusion of those other factors like previous disasters, but they have not gotten to the primary issue which is using impacts instead of needs as the measure. This is a classic example of FEMA assistance being systematically inequitable.
Above I emphasized this change would minimize the “immediate” costs for FEMA. That is because in the long-term this change will actually increase FEMA’s expenses because it will lead to more damaging disasters. When communities do not recover effectively from one disaster (including through the integration of mitigation measures), their vulnerability to the next hazard that comes along actually increases. Slower recovery times and less complete recoveries, which is what this situation would most likely lead to, would mean an increase in overall impacts. The less effective and efficient the recovery, the greater the increase in social problems and social inequity. We could expect to see increases in post-disaster mental health crises, worse physical health, more small businesses lost, worse education outcomes, loss of employment, and more. Fewer disaster declarations would also minimize the amount of funding earmarked for hazard mitigation projects being paid out of the Disaster Relief Fund. So, this change would affect not only response and recovery funding but also hazard mitigation funding.
State Deductible Program
Cuccinelli does propose an alternative to increasing the per capita indicator – developing a state deductible program. This is an old policy idea which most notably has received vocal support from President Obama’s FEMA Administrator Craig Fugate.
In fact, in 2017 he wrote a prescient op-ed warning of more drastic policy proposals looming on the horizon for which it would seem we have arrived.
“Left unaddressed, politicians and budget slashers will take drastic action to curb skyrocketing disaster costs on their own in coming years. In so doing, they'll likely hone in on simple solutions that transfer costs and miss the real opportunities we have to save taxpayer dollars while making America more resilient as well.”
The basic idea is that FEMA treats states as insurance policyholders. After a disaster, each state would be required to pay a deductible up front to unlock additional federal funding. States could count hazard mitigation (e.g., updating and enforcing building codes) and preparedness efforts (e.g., pre-disaster recovery planning) done pre-disaster towards their deductible. In this way, the theory is that a deductible model would encourage state and local governments to do more mitigation and preparedness.
Historically there has been a cautious willingness from the left to explore the state deductible idea particularly as it relates to being a way to incentivize more mitigation and preparedness. For example, here is a public comment from the Natural Resource Defense Council. The healthy dose of skepticism back in 2016 was centered around the unresolved issue of the actual cost of the state deductible. The following year (2017) FEMA put out specific numbers for state deductibles. The National Governors Association testified that although they were open to continuing discussions about the deductible there were still concerns about increasing financial burdens to the states for response and recovery costs.
My opinion on the state deductible idea has remained unchanged in the past decade. While I think it is good for the federal government to incentivize mitigation, I do not think this program will lead to a meaningful enough increase in mitigation to be worth the effort. I think it will create more work for emergency management agencies without meaningfully addressing enough of the known barriers to state and local governments doing mitigation (e.g., capacity). I think it would also be quite likely to reinforce systematic inequity across all phases. And, in the absence of it working as intended and states meeting their deduction by doing mitigation and preparedness, it will simply transfer disaster costs to the states.
It is a bit odd that Cuccinelli proposes the state deductible idea as an alternative to raising the per capita indicator. At least in the way the state deductible program was initially conceived, the primary purpose is different than that of increasing the per capita indicator. The per capita indicator is meant to primarily minimize federal spending on response and recovery whereas the state deductible idea is meant to increase state and local spending on mitigation and preparedness. Of course, there is a relationship between the two (as explained above) but at their core, they emphasize two different things. I am left wondering if this is a product of Cuccinelli’s lack of emergency management knowledge or if he is aware of a more conservative state deductible idea that has not been publicized.
Reverse Federal Cost Share
A disaster declaration does not mean the federal government is picking up the entire cost of response and recovery. Instead, FEMA has a federal “cost share” of 75/25. The current arrangement is that FEMA will pay for 75% of approved projects via the Disaster Relief Fund (DRF) while the remaining 25% of costs will be covered by nonfederal entities (i.e., state, tribal, territorial, or local governments, or by some eligible nonprofits depending on the program/project). There are multiple cost shares. Most often people are referring to the Public Assistance programs but there is also a cost share for some Individual Assistance programs (i.e., help that directly benefits disaster survivors), and mitigation funding. Cuccinelli does not specify but I assume he is referencing all cost shares.
The formal implementation of cost-sharing for broad disaster relief began in 1950 and has evolved over time. In the Stafford Act Congress codified the federal cost share at a minimum 75/25 in 1988. FEMA has the ability to waive the cost share for Public Assistance and cover up to 100% of costs themselves and Congress may waive it for other disaster funding. There are generally two scenarios where the cost share is altered. The first is when the damages are really significant. The Biden administration most recently waived the cost share for North Carolina for the first 180 days of the response to and recovery from Hurricane Helene, for example. Every state benefited from the 100% federal share during COVID. The second scenario is when economically poor communities are affected and their ability to cover the 25% cost is unreasonable.
It may sound quite generous of the federal government to take on the bulk of disaster costs via the cost share but it is, you guessed it, more complicated! FEMA is not covering 75% of the total cost of the disaster but rather 75% of what FEMA could theoretically cover based on the categories of aid approved (e.g., Public Assistance programs). In other words, there are other recovery-related expenses not accounted for by FEMA that regardless of getting a presidential declaration, state and local governments will likely need to cover on their own. For example, early estimates from North Carolina anticipated their recovery costs from Helene alone to be in the range of $50 billion with only about $14 billion being covered by the federal government and only $6 billion being covered by private sources like insurance.
Also, 25% of the costs can still be really expensive! For example, we have had at least 24 “billion-dollar” disasters in the U.S. so far this year (2024) meaning disasters that cost at least a billion dollars but almost all cost much more. Even if you are California, a billion dollars is a huge expense. Remember too that many states experience multiple disasters a year and even worse, some areas are hit repetitively. For many, coming up with the 25% is not a once-a-decade issue but rather an annual occurrence.
Cuccinelli is proposing a reversal of the federal cost share to 25/75. Instead of covering 75% of the costs, FEMA would cover only 25% leaving the remaining 75% to state/local governments. Further, instead of a 100/0 share for particularly damaging events, they will implement a 75/25 maximum for “truly catastrophic disasters”. As noted before, Cuccinelli does not define what he means by “truly catastrophic disasters”. This really matters because the severity of this policy’s implications hinges on that definition.
It is unlikely Cuccinelli is using the academic definitions of “disaster” and “catastrophe” and there are no clear and consistent definitions in existing legislation for us to use as an assumption (that’s a whole other story). What keeps coming to my mind is Trump saying Hurricane Maria was not “a real catastrophe like Katrina”. (They were both catastrophes.) Here is at least one data point that suggests right-wing politician’s threshold for “truly catastrophic disasters” may be higher than what a reasonable person would think.
Let’s do a little math.
Does Helene fit Cuccinelli’s definition of a “truly catastrophic disaster”? If so North Carolina would get 25% less than what they are receiving now. If not, they would get 75% less than what they are receiving now. In either case, FEMA would be providing less help to the affected communities. Incidentally, it is difficult to reconcile this proposal with the criticism from the far right that FEMA did not do enough to help North Carolina.
The federal government spent $4.7 trillion on COVID response and recovery via 47 federal agencies. Of this, FEMA has thus far spent just about $63 billion. If COVID is not considered a “truly catastrophic disaster” (which is a likely interpretation given the administration’s approach to public health) then states and local governments would have had to find an additional $47 billion (assuming all other federal COVID funding continued).
If this policy had been in place for Hurricane Maria and FEMA covered only 25% it would have left Puerto Rico to find $25 billion (a particularly ludicrous idea given their dire economic situation). This same policy would have left the Gulf Coast to come up with somewhere in the ballpark of $45 billion following Hurricanes Katrina and Rita in 2005. Keep in mind, this is just the funding from the DRF, both catastrophes received additional funding through other federal agencies (the changes of which I will address in the next blog post).
There are plenty of other probable catastrophic scenarios that could happen at any time for which the economic costs will be staggering. San Andreas? The Cascadia Subduction Zone in the Pacific Northwest? A direct hurricane on Miami? A long-duration blackout across the country? Bird Flu? Ebola? States cannot be expected to bear the brunt of these costs. Under this proposed policy there is no allowance for circumstances which may require 100% federal coverage. The little state of Oregon is not paying for 25% of Cascadia. Please be serious.
I also want to emphasize that under current policy, impacted communities would be required to come up with the 75% match to receive the 25% funding. In other words, if they cannot come up with the funding, they may not get any federal dollars (or only part of the possible funding). Given the much higher amount, this could be an issue for many communities. Some states are in the habit of covering cost shares for their localities while others are not. So, we would likely see significant differences from one state to the next.
Assuming state and local governments do not decide to just let recovery go unfunded, they will have to find another source for disaster funding. There are some options. Depending on what other changes were made at the federal level, they may be able to creatively secure some recovery funding from other agencies. They could turn completely to the catastrophe bond market (an extremely bad idea, IMO) as other countries have tried to do. Or they could come up with the money themselves by cutting funding from other parts of their budgets and/or raising taxes. For some states like California, this may be manageable to an extent and for a while, but it is difficult to imagine this would be sustainable. For small states and/or less wealthy states and/or those with a particularly high number of disasters, the idea that the state will supplant the full loss of federal funding is completely unrealistic.
This policy change would directly make FEMA aid distribution less equitable. Mississippi having to come up with $100 million to cover recovery costs is a disproportionate challenge than the state of California having to come up with $100 million to cover recovery costs. If recovery funding was left to the states, they would get to choose which of their communities they helped. Local governments would have to choose who within their community they would help. I can give you a list right now of who would and who would not receive that help.
The National Flood Insurance Program
Next on Cuccinelli’s list of ways to cut FEMA’s spending is the elimination of the National Flood Insurance Program. He writes:
“FEMA is also responsible for the National Flood Insurance Program (NFIP), nearly all of which is issued by the federal government. Washington provides insurance at prices lower than the actuarially fair rate, thereby subsidizing flood insurance. Then, when flood costs exceed NFIP’s revenue, FEMA seeks taxpay- er-funded bailouts. Current NFIP debt is $20.5 billion, and in 2017, Congress canceled $16 billion in debt when FEMA reached its borrowing authority limit. These subsidies and bailouts only encourage more development in flood zones, increasing the potential losses to both NFIP and the taxpayer. The NFIP should be wound down and replaced with private insurance starting with the least risky areas currently identified by the program.”
The National Flood Insurance Program (NFIP) is the primary way that Americans are able to purchase flood insurance. The NFIP is a federally backed insurance program with an origin dating back to major flood events like the 1927 Mississippi River flood. Private insurers deemed flooding an uninsurable risk and removed it from homeowners’ insurance policies. Yet, America kept flooding and by the 1960s Congress had to step in to fill the gap left by the private sector. Their solution was to create what would become today’s NFIP – a flood insurance program backed by the federal government. Since its creation, the program has been begrudgingly kicked along by Congress. It is not a business they want to be in, but it is one they have to be in because the implications of Americans not having access to affordable flood insurance would risk disrupting the housing market. My colleague and I wrote more about the history, purpose, and challenges of the program here.
Cuccinelli’s proposal is to eliminate the NFIP and have the private insurance industry take over. One of the major flaws of this plan is that private insurance companies do not seem to have much interest in taking over flood insurance. Flooding has only become more common and more expensive since the 1920s – it is still not an insurable risk if your goal is to make a profit. The handful of private companies that do offer flood insurance are largely focused on wealthy homeowners who want more than the $250,000 coverage offered by NFIP, and who want to insure things like backyard pools and second homes. That is a much different market than the one they would be entering into in the absence of NFIP. The notion that the private sector is going to take this over is particularly ludicrous in the context of the collapsing homeowners and wildfire insurance markets across the country. In Florida where insurance companies have left in droves, they have resorted to a state-backed program which is at constant risk of failing. (Incidentally, further evidence of why a national program, rather than state-level programs, is needed.)
Turning flood insurance over to private companies would mean that many people would be unable to get coverage, and where it was offered it would be extremely expensive. Or, insurance companies could offer cheap policies and then just go bankrupt in the next big flood. Either way, insurance payouts would not be coming in recovery.
I have got to tell you I really do not think they have thought through what they are suggesting here or its scale. The NFIP is a recovery lifeline for our most common hazard – flooding. Remember that around 75% of declared disasters in the U.S. are flood-related and every state has had a declared flood in just the past couple of years. If you live under the sky, you can flood. This is not just some coastal elite’s problem. Eliminating the NFIP would not affect just a few disasters, we are talking about widespread tangible consequences for homeowners appearing immediately across the country – not only in terms of not having needed money for recovery but also in the loss of home values.
A common criticism Cuccinelli repeats is that NFIP is “subsidizing” the cost of flood insurance and… yes… that is the purpose of the program. That is literally why a federally backed program had to be created. The NFIP’s debt is not evidence of failure, it is evidence that the program is working. (It is not debt either, Congress just is just choosing not to pay their bills.)
He also falls back on the common argument that by providing flood insurance the federal government is encouraging people to live in high-risk areas. This argument gives far too much credit to the program. There is a very narrow group of people who are required to carry an NFIP policy. What researchers have found is that when flood insurance is not offered it does not necessarily lead to people moving but rather, they just continue to live there without flood insurance (often because they cannot afford to move). If the government wants to change where people live, they can simply start by refusing new development in high-risk floodplains among many other policy tools.
Most people think of insurance as a hazard mitigation measure – a way to dictate where people live. FEMA does use it as a mechanism to require communities to do some flood mitigation and the elimination of the program would take away that incentive, likely leading to a decrease in mitigation at the state and local levels. The much bigger problem here, though, is what the elimination of the program would mean for recovery.
The primary benefit of the NFIP program is for recovery, not mitigation. Buying insurance is one of the best ways you can prepare yourself for recovery. It provides a (often) big pool of money for individuals who need to rebuild. (Though there are well-documented issues with insurance payouts.) So, while most look at the elimination of NFIP as a hit to mitigation (which it is) it is arguably a much bigger hit to one of the single most critical sources of funding for disaster survivors in recovery. I have addressed above why creating additional barriers to recovery is so problematic.
We do not need to spend any time imagining what it would be like for homeowners to try and recover without flood insurance because it actually happens quite frequently. In fact, it is happening right now in North Carolina. The other case to remember here is Hurricane Katrina and the levee failure where many New Orleanians had been told they did not need flood insurance because they were within the levee’s protection. When they flooded, Congress ended up having to pass additional recovery funding so survivors could rebuild. Congress still ended up having to cover significant recovery costs for individual homeowners, just without them having paid into those funds through NFIP.
Cuccinelli includes one other proposal here that is even more baffling than the full elimination of NFIP. He says private insurers should use FEMA flood map data as the foundation for their policies. In recent years FEMA has worked to update and correct their flood maps but many of them are still wrong if only because they do not accurately account for changing climate risk. Insurance companies live and die by accurately calculating risk. These maps are not accurate. A private company would have to be crazy to rely on these maps. I have to imagine forcing private insurers to use the FEMA flood maps would lead to even fewer companies offering policies.
There are very real problems with NFIP but there are also some relatively easy solutions starting with dramatically increasing the number of people in the program. In the broader national insurance landscape, we are certainly also at a point where looking at a federally backed all-hazard insurance program is likely in our future if we want to avoid crashing the housing market. As with the other policy proposals suggested here the loss of NFIP would further deepen disaster inequity.
Ragging on the NFIP is the popular thing to do. This program has been the bane of Congress’ existence for decades. They think it costs them too much money and they know those costs are going to continue to increase. They also have, to this point, however, demonstrated that they do understand the consequences of eliminating it are greater than those costs.
Eliminating Grant Funding
The final way Cuccinelli wants to cut disaster spending is through the elimination of FEMA’s grant programs. He writes:
“FEMA manages all grants for DHS, and these grants have become pork for states, localities, and special-interest groups. Since 2002, DHS/FEMA have provided more than $56 billion in preparedness grants for state, local, tribal, and territorial governments. For FY 2023, President Biden requested more than $3.5 billion for federal assistance grants. Funds provided under these programs do not provide measurable gains for preparedness or resiliency. Rather, more than any objective needs, political interests appear to direct the flow of nondisaster funds. The principles of federalism should be upheld; these indicate that states better understand their unique needs and should bear the costs of their particularized programs. FEMA employees in Washington, D.C., should not determine how billions of federal tax dollars should be awarded to train local law enforcement officers in Texas, harden cybersecurity infrastructure in Utah, or supplement migrant shelters in Arizona. DHS should not be in the business of handing out federal tax dollars: These grants should be terminated. Accomplishing this, however, will require action by Members of Congress who repeatedly vote to fund grants for political reasons. The transition should focus on building resilience and return on investment in line with real threats.”
The federal government has long used grants as a way to incentivize state and local governments to engage in disaster preparedness and mitigation. The specific grant programs, the focus of those programs, their structure, and their amounts have varied over the course of many decades. Particularly in the wake of 9/11, grants were a way for the federal government to disperse homeland security funding, including that which can be used for all-hazard preparedness, across the country.
Emergency management has a complicated relationship with homeland security. In the post-9/11 environment, the focus on terrorism was frustrating for emergency managers who were responsible for all types of hazards. The post-9/11 funding environment was chaotic and without a doubt money was wasted. However, mixed within some of these less impactful grant programs are some which are pretty single-handedly propping up state and local emergency management across the country.
Below is a list of the grant programs that FEMA currently administers. Cuccinelli recommends the termination of them all.
The elimination of any of these grant programs will lessen our national preparedness not only for terrorism but all hazard types. However, I want to highlight one grant program in particular that does not look important by its name but is beloved in emergency management – Emergency Management Performance Grants (EMPG). This grant program effectively helps build the capacity of state and local emergency management agencies. Among its many uses one of the most important is helping to pay for emergency management salaries across the country. Losing this program alone (not to mention high-impact grants like UASI) would have immediate and devastating impacts for state and local preparedness and therefore the other three phases as well.
I happen to have Boston’s 2022 budget open in front of me so we will use that as an example. (You can look this up for your own town/city/state.) The city’s emergency management budget was just about $12.5 million with about $11.3 million of that coming from federal grants (primarily UASI). If the proposed policy is implemented Boston would be left with a budget of $1.2 million. Will the city make up for this loss of funding? And while they are also likely to lose additional federal and state funding for other areas?
I do feel there is a lack of clarity on the full range of grants to be cut. First, the elimination of some of these grant programs runs counter to the proposed policy changes above. For example, Cuccinelli wants private insurers to use FEMA flood maps, yet he is cutting the RiskMAP grant? There is no explanation of how these contradicting proposals will be addressed.
Second, there is inconsistency throughout the full DHS chapter on this issue. While in the FEMA sub-section, Cuccinelli clearly states he would like to see all grants terminated, on p. 135 he references “eliminating most of DHS’s grant programs” (emphasis added). Is this a typo? Bad editing? Are there some grants he may be willing to continue to support? It is unclear.
Third are the grants that FEMA administers which are not included in this list because they are funded through other mechanisms. The biggest one is BRIC which is FEMA’s major mitigation grant program. Cuccinelli uses the language of “preparedness grants” here which has led some in emergency management to conclude that BRIC will not be included in the cuts. I, however, think it is likely that the author has no clue about the difference between a preparedness and mitigation grant and it is likely BRIC would be included.
Personnel Changes
Cuccinelli’s final paragraph of the FEMA sub-section is about changes to personnel.
“FEMA currently has four Senate-confirmed positions. Only the Administrator should be confirmed by the Senate; other political leadership need not be con- firmed by the Senate. Additionally, FEMA’s “springing Cabinet position” should be eliminated, as this creates significant unnecessary challenges to the functioning of the whole of DHS at points in time when coordinated responses are most needed.”
Here Cuccinelli seeks to undermine the checks and balances of the Senate in confirming key leadership positions within FEMA. This would increase the influence of the Trump administration over who is appointed to the agency. One lesson actually learned as a result of Hurricane Katrina and the levee failure is that FEMA’s leadership must be made up of qualified emergency managers – something even Trump adhered to during his first administration. Having multiple confirmed Senate positions also helps with continuity issues (which arose within DHS and even directly with Cuccinelli) during the last administration.
Cuccinelli also mentions here FEMA’s “springing Cabinet position”. Before 9/11 FEMA was an independent cabinet-level agency. One of the major problems with the decision to subsume FEMA within DHS, as was learned during Katrina, is that the agency no longer had a direct line to the President – which is necessary to effectively respond to large events. In the aftermath of Katrina, there were calls for FEMA to be removed from DHS but Congress would not vote for it. Instead, there was a compromise that FEMA would be able to effectively skip over the DHS secretary and go directly to the White House amid a crisis (this in practice is a bit more complicated). I believe he is recommending that the FEMA administrator should not be able to go directly to the White House but must instead report to the DHS secretary. My guess is that this proposal stems from the tensions between the DHS secretary and FEMA administrator during the last Trump administration.
Of note, this policy proposal does not align with Cuccinelli’s final major policy proposal – the removal of FEMA from DHS.
Removing FEMA from DHS
Although not included in the FEMA sub-section Cuccinelli offers one massive structural change for FEMA – removing the agency from DHS. (No, FEMA will not be eliminated despite rumors to the contrary (you are thinking of Mitt Romney’s proposal)).
“The Federal Emergency Management Agency (FEMA) be moved to the Department of the Interior or, if combined with CISA, to the Department of Transportation.”
The reason for this change appears to stem out of necessity because Cuccinelli recommends disbanding the Department of Homeland Security. The dismantling of DHS is interestingly one thing that both the left and the right agree on – although for very different reasons. There is also relatively widespread agreement within the field of emergency management that FEMA should not be in DHS but rather have its status restored as an independent cabinet-level agency as it was pre-9/11. You can read this history here.
As part of disbanding DHS Cuccinelli lays out a vague roadmap for where its agencies will go. FEMA is shipped off to either the Department of the Interior or the Department of Transportation (DOT). The deciding factor rests on whether the Cybersecurity and Infrastructure Security Agency (CISA) will be combined with FEMA. Interior if they do not combine, and DOT if they do. No, it does not make sense for FEMA to be in either.
There are no details of what it would look like for FEMA to be in either Interior or DOT so it is difficult to say whether it would be meaningfully better or worse. What I can say is that moving FEMA (or any government agency for that matter) comes with a lot of bumps and if we are going to put everyone through that turmoil we should be doing it because we have evidence that the change will meaningfully enable us to do emergency management better. That is not the case here. What both experience and research indicate is that FEMA being a cabinet-level, independent agency (CISA can come too!) best enables flexibility and improves coordination and communication during a crisis.
In Summary
Cuccinelli frames his policy proposals as addressing a series of problems with FEMA. The issues he identifies -- that state and local governments need to be more prepared for disasters, the number of disasters is increasing, and therefore the cost of response and recovery is increasing – are significant challenges for the field. Where we diverge is in our understanding of why these are problems and how to address them.
Cuccinelli has one goal: to drastically cut the amount of money that the federal government is spending on disasters. He seemingly has no interest in saving lives or property nor even minimizing the impact of disasters on the economy.
To be clear, in my rejection of these proposed policies, I am not arguing that our current emergency management system is perfect. I wrote an entire book about the flaws in our approach to emergency management and advocated for comprehensive emergency management reform to make the system more effective, efficient, and equitable. The problem is that these proposed policy changes do the opposite of that. It creates a less effective, less efficient, and less equitable emergency management system which means it makes all of us less safe.
To be clear: if the policies proposed in Project 2025 are implemented in their entirety it would represent a complete upending of the modern U.S. emergency management system. Without question, we would see higher death tolls, greater physical damage, and immense economic impacts. Our nation’s ability to prevent disasters, and prepare for the ones we cannot stop would be depleted. It would severely hamper our ability to respond to disasters, including our ability to save lives. It would eliminate the majority of the already inadequate recovery funding making disaster recovery insurmountable for many.
Whether or not these policies (in whole or in part) are implemented will likely rest on how Congress reacts. I did not have the space here to explain the mechanism for implementing each of these changes. Generally, some are internal FEMA changes that a new administrator and/or White House can direct FEMA to make independently. So, whether these changes are implemented will depend on how high up on the new administration’s list they fall.
Other changes included here will require action from Congress. This leads us to one of the big unanswered questions for all of us – will politics as usual still exist in Congress and among the states? This is something Jamelle Bouie has been exploring. If politics as usual exists there should be pushback on these changes from members of Congress (and the National Governors Association, for example). But also, I do not trust Congress. Their handling of the Disaster Relief Fund in the past few years has revealed their complete disregard for the safety and well-being of the American public. I would love to believe that Congress could be looked to as a check to balance on this extremist policy but there are many in Congress who are dissatisfied (or worse) with FEMA and who are looking for a way to punish the Agency.
Despite the best efforts of many to explain and advocate, Congress has long lacked interest and understanding of emergency management. Even those who have direct oversight of FEMA like the Senate Homeland Security Committee have demonstrated a deep lack of understanding of how FEMA operates. They pretty regularly introduce, and even pass, laws which are ineffective in addressing the problems within the agency. There are only a handful of Congresspeople who will even have a conversation about the need for emergency management reform. It is not a popular policy area (largely because it is expensive and comes with few easy solutions). Further, so far it seems that Congress will be amenable to the Trump Administration’s policy objectives.
Arguably the biggest barrier to emergency management reform in the past has been the ineffectiveness and powerlessness of the emergency management lobby. While emergency managers and others in the field (particularly disaster contractors) will likely push back on these changes it is not at all clear that they are powerful enough to make a difference (we should still try).
Now, there may be some glimmers of hope here. The issue of the NFIP is a good example. Following Sandy, Congress passed the Biggert-Waters Flood Insurance Reform Act which tried to minimize the subsidizing of flood insurance. It was so politically unpopular that they had to undo many of the changes. If the parts of the country that depend on the NFIP hold enough political power within Congress, then they may be able to prevent these changes.
That is where the real check here will come from -- the public. We face a reality in which disasters will continue to happen. The kind of changes proposed are ones that will be felt immediately and directly in communities across the country. The public has come to expect there to be a governmental response. They expect FEMA to show up. If the above policy changes are implemented, only a shadow of that response will be there. The public will assuredly be unhappy, but the question is if a coordinated effort will emerge with enough power to stop or reverse these changes.
Since the election, I have thought often of one paragraph from my book which I think aptly describes the risks of this moment:
“Despite the flaws and inadequacies of our current approach, something is still better than nothing. The emergency management system that we do have can’t be taken for granted. It is not in the Constitution that FEMA will continue to help with disaster recovery or that Congress will keep reauthorizing the National Flood Insurance Program. We have to fight to keep these programs while we fight to make them better.”
Resources To Learn More
If you are looking to learn more about the U.S. Emergency Management System as it exists today here are some other resources to check out:
I am doing an “Emergency Management System Crash Course” series on TikTok. I’ll also go through these policy changes there and keep up to date with them throughout the administration.
I did an interview a few months ago with Yale Climate Communication which outlines some of the most basic high-level emergency management reforms needed.
I wrote this New York Times Op-Ed last year specifically on the needed reforms to the U.S. Recovery System which may help you contextualize how harmful these proposed policies would be for individuals and communities undergoing recovery.
For the most in-depth look, you should read my book Disasterology: Dispatches From the Frontlines of the Climate Crisis.
This is part one of a series on how the implementation of Project 2025 would affect U.S. emergency management and national disaster risk. The other parts will be linked here once posted.