NHMA Policy Positions


NHMA FEMA RFI Comment Summary (003).docx
BCA White Paper NHMA Final RFI.docx
July 22, 2021


Comments on Draft National Mitigation Investment Strategy
March 11, 2018


Note to NHMA on the Disaster Deductible proposal from FEMA:
View full comments on this proposal

HEADLINE FOR THOSE PRESSED FOR TIME (Who isn’t?) GOOD IDEA BUT A LOT OF ISSUES IN HOW TO DO IT.

There is considerable pressure to reduce Federal spending on disaster relief, (e.g. the Heritage Foundation has short postings on their website and a long report as well, urging cuts).  They follow the GAO reports which are said to call for changing the threshold for a disaster declaration by increasing the measure of capacity of states to pay.  FEMA has instead proposed a “DISASTER DEDUCTIBLE” which would be an incentive to mitigate risks.  This was in 2016 and again in 2017 with a much more detailed model.

For the full detail, the docket for the Supplemental Advance Notice of Proposed Rule-making (SANPRM) 463 results for comments from the 2016 Advance Notice and the 2017 Supplemental Advance Notice. https://www.regulations.gov/docketBrowser?rpp=25&so=DESC&sb=commentDueDate&po=50&dct=PS&D=FEMA-2016-0003 Establishing a Deductible for FEMA’s Public Assistance Program


Community Resilience Indicators Draft Report
December 30, 2016


Letter opposing Section 5606, Senate Supplemental- levees on buy-out land: December 13, 2012