GAO 

United States Government Accountability Office

Report to Congressional Requesters

DISASTER HOUSING

FEMA Needs More 

Detailed Guidance and 

Performance 

Measures to Help 

Ensure Effective 

Assistance after Major 

Disasters 

August 2009 

GAO-09-796 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

August 2009

DISASTER HOUSING

FEMA Needs More Detailed Guidance and 

Performance Measures to Help Ensure Effective 

Highlights of GAO-09-796, a report to Assistance after Major Disasters

congressional requesters 

Concerns over the Department of 

Homeland Security’s (DHS) 

Federal Emergency Management 

Agency’s (FEMA) provision of 

temporary housing assistance, 

including travel trailers at group 

sites, after the 2005 hurricanes led 

to the development of the National 

Disaster Housing Strategy. GAO 

was asked to assess (1) the 

challenges households faced in 

transitioning to permanent housing, 

(2) the extent to which FEMA 

measured its performance in 

closing and transitioning 

households in group sites, (3) the 

strategy’s effectiveness in defining 

FEMA’s roles and responsibilities 

for closing and transitioning 

households in group sites, and 

(4) the alternatives to travel trailers 

in group sites and how well the 

strategy assessed them. GAO 

reviewed the strategy and 

interviewed officials from FEMA, 

state agencies, and selected 

nonprofit and housing research 

groups. 

What GAO Recommends

GAO recommends that the 

Secretary of the Department of 

Homeland Security direct FEMA to 

(1) develop results-oriented 

performance measures for 

assistance in group sites, 

(2) update its planning documents 

to reflect key characteristics of 

effective national strategies and 

plans, and (3) clearly describe in 

FEMA’s guidance how travel 

trailers or other options identified 

by the states can be deployed when 

other preferred options are not 

available. FEMA generally agreed 

with GAO’s recommendations. 

Households living in FEMA group sites encountered various challenges in 

transitioning to permanent housing. A significant challenge cited by several 

reports and officials GAO contacted was the availability of affordable rental 

housing. Other challenges that were cited included insufficient financing to 

fund repairs of homes, significantly higher insurance premiums, and the 

availability of full-time employment to support disaster victims’ return to 

permanent housing. 

FEMA’s overall effectiveness in measuring its performance in closing and 

transitioning households in group sites was limited because the agency’s 

measures do not provide information on program results that would be 

helpful in gauging whether the program is achieving its goal. Previously, GAO 

reported that performance measures should be aligned with program goals 

and cover the activities that an entity is expected to perform to support the 

purpose of the program. However, FEMA’s performance measures for Katrina 

and Rita group sites primarily describe program outputs and do not provide 

information on results, such as the timeliness or efficiency of closing group 

sites and transitioning households into permanent housing. Having such 

information could help identify potential problems in meeting goals and could 

be used to make decisions about resources needed and steps to be taken. 

The National Disaster Housing Strategy broadly defines FEMA’s roles and 

responsibilities for closing group sites and assisting households with the 

transition into permanent housing. Although the strategy states that FEMA is 

responsible for closing group sites and assisting households find permanent 

housing, the strategy does not reflect the key characteristics of effective 

national strategies and plans that GAO identified in prior work. For example, 

the strategy does not explain how FEMA will work with other agencies in 

closing these sites and transitioning households into permanent housing. A 

lack of a detailed plan that includes information on the steps FEMA needs to 

take to assist households with transitioning into permanent housing could 

lead to delays in the future in helping disaster victims return to more stable 

and conventional living arrangements. 

Officials contacted and reports reviewed by GAO identified a number of 

housing options that could serve as alternatives to travel trailers in group 

sites—for example, providing rental assistance for existing housing and 

repairing damaged rental housing. However, FEMA’s strategy does not assess 

alternatives, in part, because evaluations are ongoing. Also, it does not 

provide clear guidance on the specific temporary housing options that states 

can use instead of travel trailers while FEMA completes these evaluations. 

Without more specific information on what these temporary housing options 

are, including alternatives to travel trailers, state officials will not have the 

information needed to expedite the selection of temporary housing options. 

As a result, FEMA and the states may not be fully prepared to quickly respond 

to the temporary housing needs of those displaced by major disasters. 

View GAO-09-796 or key components.

For more information, contact Mathew J. 

Scirè at (202) 512-8678 or sciremj@gao.gov. 
Page i GAO-09-796 

Contents 

Letter 1

Background 3 

Households in FEMA Group Sites Have Faced Various Challenges 

in Returning to Permanent Housing 9 

FEMA Reports Basic Activities in Closing Group Sites, but Efforts 

to Measure Results Are Limited 20 

The Housing Strategy Defines FEMA’s Roles and Responsibilities 

for Closing Group Sites, but Does Not Have Key Characteristics 

of an Effective Strategy 25 

FEMA’s Strategy Does Not Identify Alternatives or Provide Clear 

Guidance on Using Currently Available Options 31 

Conclusions 42 

Recommendations for Executive Action 43 

Agency Comments and Our Evaluation 44 

Appendix I Scope and Methodology 46 

Appendix II Comments from the Department of Homeland 

Security 51 

Appendix III GAO Contact and Acknowledgments 53 

Figures 

Figure 1: Examples of Manufactured Housing and Recreational 

Vehicles 5 

Figure 2: Temporary Housing Unit Placed on a Private Site in New 

Orleans, Louisiana 6 

Figure 3: Temporary Housing Units Placed at a FEMA Group Site in 

D’Iberville, Mississippi 7 

Figure 4: Geographic Dispersion of FEMA Group Sites Following 

Hurricanes Katrina and Rita 8 

Figure 5: Predisaster Tenure Status of Households Living in FEMA 

Group Sites 9 

Figure 6: Comparison of Group Site Household Reported Average 

Income with Statewide Average Income in Calendar Year 

2005 10 

 Disaster Housing 
Figure 7: HUD Fair Market Rents for a Two-Bedroom Unit in 

Selected Gulf Coast Metropolitan Areas, Fiscal Years 

2005-2009 12 

Figure 8: Unemployment Rates in Selected Gulf Coast Metropolitan 

Areas 19 

Figure 9: Performance Measurement Model 21 

Abbreviations 

AHPP Alternative Housing Pilot Program 

CDBG Community Development Block Grant 

DHAP Disaster Housing Assistance Program 

DHS Department of Homeland Security 

FEMA Federal Emergency Management Agency 

FRRATS FEMA Response and Recovery Applicant Tracking System 

GCRO Gulf Coast Recovery Office 

GO Zone Gulf Opportunity Zone Act of 2005 

GPRA Government Performance and Results Act of 1993 

HFA Housing Finance Agency 

HUD Department of Housing and Urban Development 

JHSG Joint Housing Solutions Group 

LIHTC Low-Income Housing Tax Credit 

MSA metropolitan statistical area 

NEMIS National Emergency Management Information System 

NIMBY not in my backyard 

OIG Office of Inspector General 

VA Department of Veterans Affairs 

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Page ii GAO-09-796 Disaster Housing
Page 1 GAO-09-796 

 

United States Government Accountability Office

Washington, DC 20548 

 

August 28, 2009 

The Honorable Joseph I. Lieberman 

Chairman 

Committee on Homeland Security 

 and Governmental Affairs 

United States Senate 

The Honorable Mary L. Landrieu 

Chair 

Subcommittee on Disaster Recovery 

Committee on Homeland Security 

 and Governmental Affairs 

United States Senate 

In August 2005, Hurricane Katrina destroyed or made uninhabitable an 

estimated 300,000 homes, leaving thousands of people in need of 

temporary housing across the Gulf Coast region of the United States. 

Hurricane Rita added to the devastation in September 2005. The Federal 

Emergency Management Agency (FEMA), whose mission includes leading 

the federal response to natural disasters, provided direct housing 

assistance to about 143,500 households affected by these storms—

primarily in the form of temporary housing units, such as travel trailers or 

manufactured homes. In most cases, FEMA placed households in units on 

private property near their homes so that they had a place to live close by 

while making repairs. However, FEMA also placed about 25,000 

households in units at more than 700 group sites, including temporary 

sites that the agency constructed on stadium grounds and school fields 

and preexisting trailer parks.1

 More than 3 years after the storms, FEMA 

has moved most households from nearly all of these sites, but 348 

households continued to live in 101 group sites located in Louisiana and 

Mississippi as of June 18, 2009. 

In 2006, Congress enacted the Post-Katrina Emergency Management 

Reform Act (Post-Katrina Act), which included several provisions related 

to FEMA’s efforts to provide housing assistance to individuals affected by 

1

FEMA refers to preexisting trailer parks used to house disaster victims as “commercial 

sites.” For the purposes of this report, our use of the term “group sites” includes both 

FEMA-constructed and preexisting commercial sites, unless otherwise indicated. 

 Disaster Housing 
 

Hurricanes Katrina and Rita and future disasters.2 The act also directed 

FEMA to develop a national disaster housing strategy to outline the most 

efficient and cost-effective federal programs for meeting the short- and 

long-term housing needs of individuals and households affected by a major 

disaster. 

You asked GAO to review several issues related to the federal 

government’s efforts to assist households with recovering and rebuilding 

their lives following Hurricanes Katrina and Rita, particularly its efforts for 

those households living in travel trailers in group sites. This report focuses 

on FEMA’s efforts to help these households move to permanent housing.3

Specifically, this report examines (1) challenges that households living in 

group sites faced in transitioning to permanent housing;4

 (2) the extent to 

which FEMA effectively measured its performance in closing group sites 

and assisting households with transitioning into permanent housing; 

(3) the National Disaster Housing Strategy’s effectiveness in defining 

FEMA’s roles and responsibilities for closing group sites and assisting 

households with transitioning to permanent housing; and (4) the 

alternatives to travel trailers in group sites when providing temporary 

housing after major disasters, how they compare with respect to identified 

policy factors, and how well FEMA’s National Disaster Housing Strategy

assessed these alternatives. 

To identify challenges that households living in group sites faced in 

transitioning to permanent housing, we examined reports related to the 

federal government’s response to Hurricanes Katrina and Rita and its 

efforts to provide housing assistance in group sites. We also interviewed 

officials from federal, state, and local governments and nonprofit 

organizations to obtain their perspectives on the challenges that these 

households faced. To assess the extent to which FEMA effectively 

measured its performance in closing group sites and assisting households 

that lived in these sites with transitioning into permanent housing, we 

 

2

The Post-Katrina Act was enacted as title VI of the Department of Homeland Security 

Appropriations Act, 2007, Pub. L. No. 109-295, 120 Stat. 1355 (2006). 

3

GAO has also conducted related work on the federal government’s efforts to assist 

households living in group sites with employment, services for families with children, and 

transportation. See GAO, Disaster Assistance: Federal Efforts to Assist Group Site 

Residents with Employment, Services for Families with Children, and Transportation, 

GAO-09-81 (Washington, D.C.: Dec. 11, 2008). 

4

FEMA defines “permanent housing” as safe, sanitary, and secure housing that can be 

sustained without continued disaster-related assistance. 

Page 2 GAO-09-796 Disaster Housing
 

examined annual performance plans, weekly performance reports, and 

other documents related to the measures that FEMA developed to assess 

its performance and compared these measures with the key 

characteristics of successful performance measures identified in prior 

GAO work. To determine the National Disaster Housing Strategy’s

effectiveness in defining FEMA’s roles and responsibilities for closing 

group sites and assisting households that lived in these sites with 

transitioning to permanent housing, we reviewed FEMA’s strategies, 

policies and procedures, and relevant legislation that describe FEMA’s 

authority to provide direct housing assistance. Additionally, we drew upon 

our prior work to compare the relevant sections of the strategy with the 

characteristics of an effective national strategy. To determine the 

alternatives to travel trailers in group sites and examine how they aligned 

with identified policy factors, such as cost-effectiveness and efficiency, we 

reviewed prior government and academic reports and interviewed officials 

from FEMA, state housing agencies in the Gulf Coast region, and selected 

nonprofit and housing research groups. We also reviewed the strategy to 

determine how well it assessed alternatives to group sites in terms of the 

identified policy factors. We tested the reliability of certain FEMA data we 

discuss in this report as part of a previous study and found the data to be 

reliable. We determined that the other data we discuss in this report were 

sufficiently reliable for our purposes. 

We conducted this performance audit from January 2008 through August 

2009, in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. Appendix I discusses our 

scope and methodology in more detail. 

The Robert T. Stafford Disaster Relief and Emergency Assistance Act (the 

Stafford Act) grants the principle authority for the President to provide 

assistance in mitigating, responding to, and preparing for disasters and 

emergencies, such as earthquakes, hurricanes, floods, tornadoes, and 

terrorist acts.5

 FEMA administers the Stafford Act and provides direct 

housing assistance (e.g., travel trailers and manufactured homes) under its 

Background 

 

5

The Stafford Act is codified as amended at 42 U.S.C. § 5121 et seq. 

Page 3 GAO-09-796 Disaster Housing
 

Individuals and Households Program. FEMA provides these units at no 

charge to disaster victims who cannot use financial assistance to rent 

alternate housing because such housing is not available. The Stafford Act 

limits direct housing assistance to an 18-month period, after which FEMA 

may charge rents at the fair market rent levels established by the 

Department of Housing and Urban Development (HUD), but the President 

can also extend the initial 18-month period because of extraordinary 

circumstances.6

According to FEMA guidance, manufactured housing and recreational 

vehicles are the two most common forms of temporary housing units (see 

fig. 1). Manufactured housing is factory-built housing designed for longterm residential use. The term “mobile home” is sometimes used to refer 

to manufactured homes. In addition, this type of housing must be located 

on sites that are not in a designated floodplain area. Recreational vehicles, 

which include park model and travel trailers, are designed for short-term 

use when no other options are available. Following a disaster, the units 

may be a short-term housing option for households wanting to remain on 

an existing property or nearby while permanent housing is being restored, 

but the terrain or lot size prevents deployment of manufactured housing. A 

park model, which is generally larger than a travel trailer, is built on a 

single chassis, mounted on wheels, and has 400-square feet or less of living 

space. 

 

6

HUD annually estimates the fair market rents for all metropolitan and nonmetropolitan 

areas nationwide for the Housing Choice Voucher program. Fair market rents represent the 

cost of modest housing (equal to the 40th percentile in the distribution of rents) in specific 

markets. 

Page 4 GAO-09-796 Disaster Housing
 

Figure 1: Examples of Manufactured Housing and Recreational Vehicles 

Source: FEMA (top: Patsy Lynch; middle: Susie Shapira; bottom: Mark Wolfe).

Two-bedroom manufactured (mobile) home

Travel trailer

Park model

Page 5 GAO-09-796 Disaster Housing
 

FEMA can place temporary housing units on a private site or in a group 

site configuration. 

• Private site: Temporary housing unit is placed on an individual’s private 

property if the site is feasible and the local authorities approve. The unit 

can also be placed on individual private property that is not owned by the 

applicant, if the owner allows FEMA to place the unit at no cost to the 

agency (see fig. 2). 

Figure 2: Temporary Housing Unit Placed on a Private Site in New Orleans, 

Louisiana 

Source: GAO.

• Group site: Temporary housing unit is placed at a site that FEMA has built 

to house multiple households. FEMA built these sites in open space 

locations, including parks, playgrounds, ball fields, and parking lots 

following Hurricane Katrina (see fig. 3). FEMA can also place units at a 

commercial manufactured housing or recreational vehicle park that 

already has utilities (water, electric, and sewer/septic) for existing lots. 

The park management must be willing to lease the lots to FEMA at a fair 

and reasonable cost for the area. According to FEMA, the agency’s policy 

is to use existing commercial parks whenever possible, rather than to 

build sites. 

Page 6 GAO-09-796 Disaster Housing
 

Figure 3: Temporary Housing Units Placed at a FEMA Group Site in D’Iberville, 

Mississippi 

FEMA placed temporary housing units on private sites for about 115,400 

(80 percent) of the households that received direct housing assistance 

following Hurricanes Katrina and Rita. FEMA placed about 25,000 

households that received such assistance in temporary housing units at 

group sites located across Alabama, Louisiana, Mississippi, and Texas. 

Figure 4 illustrates the geographic dispersion of these sites. 

Source: FEMA (Mark Wolfe).

Page 7 GAO-09-796 Disaster Housing
 

Figure 4: Geographic Dispersion of FEMA Group Sites Following Hurricanes Katrina and Rita 

Sources: FEMA (data); MapInfo (map).

0 

1 to 10 

11 to 20 

21 or more

Mi Alabama ssissippi

Louisiana

Texas

Group sites

Most of the households that FEMA placed in group sites following 

Hurricanes Katrina and Rita reported being predisaster renters. Figure 5 

shows that about 72 percent of group site households in Louisiana and an 

even higher percentage of group site households in Mississippi (about 

84 percent) reported being predisaster renters. In comparison, renters 

made up less than one-third of all households in both states prior to the 

hurricanes. 

Page 8 GAO-09-796 Disaster Housing
 

Figure 5: Predisaster Tenure Status of Households Living in FEMA Group Sites 

Louisiana

Group sites

Statewide

Mississippi

28.0%

67.8%

71.9%

16.3%

83.5%

30.1%

69.9%

32.2%

Predisaster renters

Predisaster homeowners

Source: FEMA (group site data); Census Bureau (statewide data).

Households living in FEMA group sites encountered a variety of 

challenges in transitioning to permanent housing. According to officials 

we contacted and reports we reviewed, many of the households that lived 

in group sites following Hurricanes Katrina and Rita had low incomes, 

were elderly, or had a disability.7

 As a result, these households were likely 

to experience difficulties in finding and transitioning to permanent 

housing. FEMA expects disaster victims who receive housing assistance to 

take an active role in finding housing and rebuilding their lives. 

Specifically, FEMA requires households receiving this type of assistance to 

develop within a reasonable amount of time a plan for moving into 

permanent housing that is similar to their predisaster housing.8

 However, 

according to some officials we contacted, households living in group sites 

Households in FEMA 

Group Sites Have 

Faced Various 

Challenges in 

Returning to 

Permanent Housing 

 

7

See appendix I of this report for a list of all the entities we interviewed to identify 

challenges that households living in group sites faced in transitioning to permanent 

housing. 

8

44 C.F.R. § 206.114(b)(1). 

Page 9 GAO-09-796 Disaster Housing
 

were not able to plan their recovery and were likely to face difficulties in 

accessing aid from federal programs—a problem that was exacerbated by 

the disaster—because these households were the hardest to serve. 

According to these officials, these households generally required 

additional services or assistance to support their transition into permanent 

housing. 

Specifically, our prior work found that although the majority of heads of 

households reported being employed when they applied for FEMA 

assistance, approximately 65 percent reported earning less than $20,000.9

About one-fifth reported no income and some of these individuals were 

retired or had disabilities. As shown in figure 6, the reported average 

income of households on group sites in Louisiana and Mississippi was 

about $24,000 and $30,000, respectively, or less than one-half of the 

Louisiana state average and less than two-thirds of the Mississippi state 

average. According to FEMA, these limited means led to concerns among 

some households about moving out of the sites and finding housing that 

they could afford. Furthermore, some of these households could not 

afford either security deposits for a rental unit or furniture. 

Figure 6: Comparison of Group Site Household Reported Average Income with 

Statewide Average Income in Calendar Year 2005 

Group site location

$45.0

$50.7

Average reported income (dollars in thousands)

Source: FEMA (group site income); Census Bureau (statewide income).

0 10 20 30 40 50 60

Louisiana

Mississippi

Statewide mean income (2005)

Group site mean income

 

9

See GAO-09-81. The demographic data represent information that individuals self-reported 

as part of their application for FEMA assistance. 

Page 10 GAO-09-796 Disaster Housing
 

FEMA also said that households facing these challenges may be more 

reluctant to find and pay for permanent housing. While FEMA does not 

update demographic data on households on group sites to reflect current 

employment status or income levels, agency officials stated that those who 

remained in the sites the longest were the hardest-to-serve people, 

including the unemployed, elderly, or persons with disabilities. 

In the following sections, we describe other challenges that households 

living in group sites may have likely faced in transitioning to permanent 

housing. Although these other challenges are not unique to group site 

households and affected disaster victims in the Gulf Coast region, many of 

these challenges would likely have a more acute impact on households 

living in group sites. 

Availability of Affordable 

Rental Housing Was a Key 

Challenge in Transitioning 

to Permanent Housing 

According to several federal and state officials we contacted and reports 

we reviewed, one commonly cited challenge displaced households faced 

was finding affordable rental housing, since rents increased significantly 

following the storms in certain Gulf Coast metropolitan areas. For 

example, HUD’s fair market rent for a two-bedroom unit in the New 

Orleans-Metairie-Kenner metropolitan area increased from $676 to $1,030, 

or about 52 percent, between fiscal years 2005 and 2009 (see fig. 7). In 

addition, HUD’s fair market rent for a two-bedroom unit in the GulfportBiloxi metropolitan area increased from $592 to $844, or about 43 percent, 

over the same time period. Figure 7 also shows that the Beaumont-Port 

Arthur and Mobile metropolitan areas experienced relatively smaller 

increases in fair market rent between fiscal years 2005 and 2009 (about 

22 and 20 percent, respectively). Rents did not increase as much as in 

Beaumont-Port Arthur as they did in New Orleans-Metairie-Kenner or 

Gulfport-Biloxi, because relatively high vacancy rates prior to fiscal year 

2005 likely softened the effect of the permanent loss of rental units and 

temporary removal of rental units from the market following Hurricane 

Rita.10 In comparison, average rents in cities nationwide increased by 

about 12 percent from fiscal years 2005 through 2008 (the last year for 

which data are available), according to the Consumer Price Index. 

 

10U.S. Department of Housing and Urban Development, Comprehensive Market Analysis: 

Beaumont-Port Arthur, TX (Washington, D.C.: June 1, 2008). 

Page 11 GAO-09-796 Disaster Housing
 

Figure 7: HUD Fair Market Rents for a Two-Bedroom Unit in Selected Gulf Coast 

Metropolitan Areas, Fiscal Years 2005-2009 

0

200

400

600

800

1,000

1,200

2005 2006 2007 2008 2009

Fair market rent

Fiscal year

Source: HUD.

Beaumont-Port Arthur, Texas

Mobile, Alabama

Gulfport-Biloxi, Mississippi

New Orleans-Metairie-Kennar, Louisiana

Metropolitan area

Two key factors that contributed to these higher rents were a decreased 

supply of affordable rental units and an increased demand for undamaged 

rental units. Specifically, according to estimates by FEMA, Hurricanes 

Katrina and Rita caused major or severe damage to 112,000 rental units 

across the Gulf Coast region. According to HUD, 75 percent of the 

damaged rental units were occupied by low-income households. An 

increased demand for rental units also contributed to rent increases. 

According to The Urban Institute, this demand was driven by construction 

workers who moved to the area to accelerate recovery and by displaced 

Page 12 GAO-09-796 Disaster Housing
 

renters and homeowners who needed temporary rental units in the area 

while their homes were being repaired.11

FEMA staff working to assist households living in group sites cited 

additional difficulties that group site households faced in finding 

permanent housing following Hurricanes Katrina and Rita. For example, 

some households reported to FEMA that there was a lack of available 

affordable rental housing in areas where they wanted to remain, 

particularly in some small towns. Other households reported to FEMA that 

while they were able to find rental housing, the units were either not 

habitable or located in unstable or abandoned neighborhoods. 

Also affecting the limited supply of rental housing were the following two 

factors: the slow pace of rental housing construction under key federal 

programs and the decision by states to focus the majority of federal funds 

on repairing homeowner units, rather than rental units. The Low-Income 

Housing Tax Credit (LIHTC) program provides an incentive for the 

development of rental housing that is affordable to low-income 

households and has been a major source of such housing. State housing 

finance agencies (HFA) must award credits to developers of qualified 

projects, and developers either use the credits or sell them to investors to 

raise capital (i.e., equity).12 The equity raised by the tax credits reduces the 

need for debt financing, and, as a result, these properties can offer lower, 

more affordable rents. After the 2005 hurricanes, Congress passed the Gulf 

Opportunity Zone Act of 2005 (GO Zone), which temporarily increased the 

amount of allocated tax credits for the five states along the Gulf Coast by a 

total of about $330 million.13

Limitations in Developing 

Affordable Rental Housing with 

Federal Subsidies 

We reported in July 2008 that although the Gulf Coast states had awarded 

nearly all of their GO Zone LIHTCs, few of the units funded by these 

 

11The Urban Institute, Affordable Rental Housing in Healthy Communities: Rebuilding 

After Hurricanes Katrina and Rita (May 2007). 

12In general, investors can claim credits on the qualified basis of the property—that is, total 

development cost (excluding land and other certain costs) of the low-income units. The 

investors receive approximately 9 percent of the qualified basis in tax credits annually for 

10 years. 

13GO Zone LIHTCs were provided to the five eligible states in addition to their regular 

annual allocations. The 2006 through 2008 GO Zone LIHTC authority was about 75 percent, 

567 percent, and 523 percent greater than the regular LIHTC authority that Alabama, 

Louisiana, and Mississippi received in the same period, respectively. Also, Florida and 

Texas each received $3.5 million in GO Zone tax credit authority. 

Page 13 GAO-09-796 Disaster Housing
 

credits were in service as of April 2008.14 Since that time, Louisiana and 

Mississippi, which received the largest amounts of GO Zone authority, 

have each placed additional units in service. However, neither state had 

placed more than 35 percent of planned units in service as of December 

2008. While LIHTC-funded units are generally required to be placed in 

service within 2 years of credit allocation, Congress extended this 

requirement for units funded with GO Zone LIHTCs, which must be placed 

in service before January 1, 2011. According to HFA officials, the declining 

market value of tax credits has reduced the amount of equity developers 

receive from investors for each dollar in tax credit awarded.15 As a result, 

developers must seek additional funding sources to make up for the equity 

shortfall, contributing to significant delays in closings, according to state 

officials. Other issues that have impeded the timely development of LIHTC 

units include the need to address environmental issues and increases in 

the total costs to develop projects because of the high costs of labor, 

materials, insurance, and land. 

Much of the disaster assistance provided through HUD’s Community 

Development Block Grant (CDBG) program, which provides flexible relief 

and recovery grants to devastated communities, was targeted to 

homeowners, with a small percentage of program funds set aside for 

owners of rental properties.16 Between December 2005 and November 

2007, Congress appropriated a total of $19.7 billion in disaster CDBG funds 

to states affected by the 2005 hurricanes, of which not less than $1 billion 

was designated to repair or replace the affordable rental housing stock, 

 

14GAO, Gulf Opportunity Zone: States Are Allocating Federal Tax Incentives to Finance 

Low-Income Housing and a Wide Range of Private Facilities, GAO-08-913 (Washington, 

D.C.: July 16, 2008). 

15Alex Frangos, “Credit Losses Stall Affordable-Housing Projects,” The Wall Street Journal 

(Mar. 12, 2008) Eastern edition, B.1; and Rebecca Mowbray, “Market Crunch Hinders New 

Housing,” The Times Picayune (Mar. 28, 2008). 

16The CDBG program, administered by HUD, is the federal government’s largest and most 

widely available source of financial assistance to support state and local governmentdirected neighborhood revitalization, housing rehabilitation, and economic development 

activities. The CDBG program has been used frequently by the federal government to 

respond to natural and man-made catastrophes. 

Page 14 GAO-09-796 Disaster Housing
 

including public and HUD-assisted housing.17 Local and state officials 

exercise a great deal of discretion in determining the use of the funds 

under this program. Three states (Louisiana, Mississippi, and Texas) used 

most of the CDBG funds to implement homeowner assistance grant 

programs to help homeowners cover the gap between their available 

financial resources and the cost to repair and replace their damaged 

dwellings. For example, as of January 2009, Louisiana had targeted 

$10.5 billion in CDBG funds (out of the total $13.4 billion) to housing 

assistance programs, and, of this amount, the state targeted about 

$8.6 billion, or 86 percent, to the Road Home Program (the state’s 

Homeowner Assistance Program). In contrast, the state set aside about 

$1.3 billion, or 13 percent, of its housing allocation for programs that 

targeted rental housing. Furthermore, while about 7 percent of the 

Homeowner Assistance Program funds remained unexpended as of the 

beginning of 2009, 80 percent of the funds set aside for rental housing had 

not been spent. 

Public housing agencies have faced considerable challenges in obtaining 

funding for the recovery of public housing units. Public housing is an 

important source of affordable housing for low-income households in the 

Gulf Coast region. The Gulf Coast states experienced a decline in the 

number of available units as a result of the storms, especially in the New 

Orleans area. Prior to Hurricane Katrina, the Housing Authority of New 

Orleans managed over 7,000 units of public housing in 10 different 

developments. Hurricane Katrina damaged about 80 percent of these units 

(approximately 5,600 units). In the aftermath, HUD officials stated that the 

department did not have sufficient program funds to repair and rebuild 

these units, and that the public housing agencies did not have sufficient 

insurance to cover the costs.18

 

17Congress appropriated $11.5 billion in CDBG assistance in the Defense Appropriations 

Act for fiscal year 2006, Pub. L. No. 109-148, and $5.2 billion in the Emergency 

Supplemental Appropriations Act of Defense, the Global War on Terror, and the Hurricane 

Recovery Act of 2006, Pub. L. No. 109-234. In addition, Congress provided $3 billion in 

CDBG funding for the Louisiana homeowner assistance grant program, through the 

Department of Defense Appropriations Act for fiscal year 2008, Pub. L. No. 110-116. 

18A 2003 FEMA policy states that it cannot fund the repair and rebuilding of public housing 

units through its Stafford Act authorities (see FEMA Policy 9523.7 and FEMA/HUD 

memorandum of understanding entitled Coordination of HUD and FEMA Disaster 

Assistance to Public Housing Authorities (PHAs) at 

http://www.fema.gov/government/grant/pa/9523_7b.shtm). Although recent changes in law 

now appear to allow FEMA funding of public housing units after a presidentially declared 

disaster, these changes do not apply retroactively to units affected by the 2005 hurricanes. 

Page 15 GAO-09-796 Disaster Housing
 

A large portion of households that were displaced by the Gulf Coast 

hurricanes were renters, and given the challenges faced in developing 

affordable rental housing with federal subsidies, concerns have been 

raised about differences in the treatment of homeowners and rental 

property owners. GAO is conducting a separate review to (1) identify the 

federal assistance for permanent housing that was provided to rental 

property owners and to homeowners affected by the Gulf Coast 

hurricanes, (2) examine the extent to which federally funded programs 

responded to the needs of rental property owners and homeowners, and 

(3) describe the differences in the challenges faced in utilizing federal 

assistance for permanent housing and the options to mitigate these 

challenges. 

According to many officials we contacted, another significant obstacle to 

building affordable rental housing was opposition to the development of 

such housing by local communities—a problem typically referred to as 

“not in my backyard” or “NIMBY.” Opposition by local residents and public 

officials to specific types of housing in their neighborhood or communities 

is a long-standing issue in the development of affordable housing. 

Communities typically resist the development of affordable rental housing 

because of concerns about potential adverse impact on property values 

and community characteristics. Such opposition can manifest itself in 

restrictive land-use and development regulations that add to the cost of 

housing or discourage the development of affordable housing altogether. 

During the period after the Gulf Coast hurricanes, some officials we 

contacted and reports we reviewed explained that local opposition had 

slowed and, in some instances, stopped the development of affordable 

rental housing. For example, a nonprofit organization had planned to use 

LIHTCs to build an apartment complex for low-income elderly households 

in New Orleans to replace a complex destroyed by the hurricanes. 

However, according to an official from a New Orleans nonprofit 

organization, the local government passed a resolution that prohibited 

LIHTC developments and also engaged in a land-use study at the site of the 

proposed development that appeared to be timed to terminate the project. 

A report on the status of Mississippi’s housing recovery efforts since the 

Gulf Coast hurricanes cited NIMBY as one of the key barriers to 

addressing the state’s projected shortfall in the number of affordable 

Community Resistance to the 

Development of Affordable 

Housing 

Page 16 GAO-09-796 Disaster Housing
 

rental housing units that it had planned to restore under the LIHTC 

program.19

Rebuilding Costs, 

Escalating Insurance 

Premiums, and 

Unemployment Also 

Affected Disaster Victims’ 

Efforts to Return to 

Permanent Housing 

On the basis of our discussions with officials and review of reports, we 

found that disaster victims encountered other challenges in returning to 

permanent housing, including households living in group sites. First, 

several sources indicated that disaster victims who owned homes faced 

significant challenges in financing repairs. For example, according to a 

Department of Homeland Security (DHS) Office of Inspector General 

(OIG) report, a December 2007 survey of FEMA field staff in Louisiana 

indicated that homeowners faced financial obstacles, including 

insufficient insurance coverage and limited Road Home Program funding, 

in repairing their homes.20 Similarly, a 2008 study of the post-Katrina 

housing recovery in Louisiana found that nearly three-fourths of Road 

Home applicants would still face a gap between their rebuilding resources 

and the cost to rebuild, leaving them short of the resources needed to 

repair their dwellings.21 The DHS OIG report also found that high 

construction costs, competition for available contractors, and new disaster 

mitigation requirements compounded these financial problems.22

According to some sources, the longer time frames and increased 

construction costs to repair damaged dwellings also impacted landlords, 

which in turn increased housing costs for renters. 

A second commonly cited challenge that disaster victims faced in 

returning to permanent housing was significantly higher insurance 

premiums. According to a report from the Louisiana Housing Finance 

 

19Mississippi Center for Justice, prepared for the Steps Coalition, Is Mississippi Building 

Back Better Than Before: Problems and Solutions Regarding Mississippi’s Use of CDBG 

Disaster Recovery Fund (Biloxi, Miss.: Aug. 29, 2008). 

20See Department of Homeland Security, Office of Inspector General, Federal Emergency 

Management Agency’s Exit Strategy for Temporary Housing in the Gulf Coast Region, 

OIG-09-02 (Washington, D.C.: Oct. 2, 2008). The Louisiana Road Home Program, which is 

mainly funded with CDBG funds, provided eligible homeowners affected by Hurricanes 

Katrina or Rita with compensation grants up to $150,000 for their losses and to help them 

get back into their homes. Similarly, Mississippi’s Homeowner’s Grant Program provided 

eligible homeowners with compensation grants of up to $150,000 for losses not covered by 

their homeowners insurance or FEMA assistance. 

21PolicyLink, A Long Way Home: The State of Housing Recovery in Louisiana 2008 

(online publication). 

22OIG-09-02. 

Page 17 GAO-09-796 Disaster Housing
 

Agency, premiums for homeowners insurance escalated to as much as 

four times their pre-Katrina level for certain areas in Louisiana that were 

severely impacted by the storm, putting insurance out of reach for most 

low- and moderate-income households.23 According to some officials we 

contacted, some landlords passed the escalating costs of insurance to 

rental households through increased rents. In addition, some insurance 

companies suspended sales of new homeowner policies in all or parts of 

the Gulf Coast region following Hurricanes Katrina and Rita, making it 

increasingly difficult for households to obtain insurance coverage in these 

areas. 

Finally, many households faced challenges in finding full-time employment 

to support a return to permanent housing. Following Hurricane Katrina in 

late August 2005 and Hurricane Rita in September 2005, unemployment 

rates increased significantly across the Gulf Coast region. For example, 

the unemployment rate in the New Orleans-Metairie-Kenner metropolitan 

area increased from 4.9 percent in August 2005 to more than 15.2 percent 

in September 2005, and the unemployment rate remained above preKatrina levels until March 2006 (see fig. 8). In the Gulfport-Biloxi 

metropolitan area, the unemployment rate increase following the storm 

was more significant, since the rate increased from 5.8 percent in August 

2005 to more than 23.2 percent in September 2005. Moreover, the 

unemployment rate remained above pre-Katrina levels for 1 year following 

the storm. 

 

23GCR & Associates, Inc., Louisiana and New Orleans Metro Housing Needs 

Assessment—Louisiana Housing Finance Agency (New Orleans, La.: Feb. 15, 2008). 

Page 18 GAO-09-796 Disaster Housing
 

Figure 8: Unemployment Rates in Selected Gulf Coast Metropolitan Areas 

0

5

10

15

20

25

Aug. Sept. Oct. Nov. Dec. Jan. Feb. Mar. Apr. May June July Aug. Aug. Aug.

Unemployment rate

Source: Department of Labor, Bureau of Labor Statistics.

2005 2006 2007 2008

Beaumont-Port Arthur, TX

New Orleans-Metairie-Kenner, LA

United States

Mobile, AL

Gulport-Biloxi, MS 

Month/Year

In 2008, we reported that approximately 21 percent of those households 

living in group sites reported no source of employment, and that some of 

those households reported having a disability or being retired.24 While 

FEMA did not update data on group site residents to reflect current 

employment status, some state and FEMA officials we contacted said that 

those who remained in the sites the longest were those with limited 

income and limited choices to find stable employment, including the 

elderly and persons with disabilities. Similarly, according to an April 2007 

survey of FEMA group sites in Louisiana, more than two-thirds of the 

respondents were unemployed, and most of these respondents were not 

looking for employment.25 Most of those respondents not looking for 

employment said they were disabled or had major health limitations. 

 

24See GAO-09-81. These data represent information that individuals self-reported as part of 

their application for FEMA assistance. 

25Louisiana State University Agricultural Center, Louisiana FEMA Park Survey, Interim 

Report (April 2007). 

Page 19 GAO-09-796 Disaster Housing
 

FEMA’s overall effectiveness in measuring its performance in closing 

group sites and transitioning households into permanent housing was 

limited. While FEMA made some efforts to measure its progress, its 

measures did not provide the information on program results that was 

needed to assess the agency’s performance in achieving its goal of “helping 

individuals and communities affected by federally declared disasters 

return to normal functioning quickly and efficiently.” Under the provisions 

of the Government Performance and Results Act of 1993 (GPRA), federal 

agencies are required to measure and report the performance of their 

programs.26 GPRA was designed to inform congressional and executive 

decision making by providing objective information on the relative 

efficiency and effectiveness of federal programs and spending. Previously, 

we have reported that for performance measures to be useful, they should 

be linked or aligned with program goals, cover the activities that an entity 

is expected to perform to support the program’s purpose, and have a 

measurable target.27 These measures can capture several aspects of 

performance, including activities, outputs, outcomes, and impact (see 

fig. 9). Based on our past work, federal agencies have faced challenges in 

identifying program goals and performance measures that go beyond 

summarizing program activities (e.g., the number of clients served) to 

distinguishing desired outcomes or results (e.g., improving economic selfsufficiency among clients served).28 As figure 9 shows, having measures 

that describe outcomes and impact helps describe the extent to which the 

program is effective in achieving its policy objectives. In the past, we have 

found that performance measures are an important results-oriented 

management tool that can enable managers to determine the extent to 

which desired outcomes are being achieved. Results-oriented measures 

FEMA Reports Basic 

Activities in Closing 

Group Sites, but 

Efforts to Measure 

Results Are Limited 

 

26Pub. L. No. 103-62, 31 U.S.C. 1115 et seq. and 5 U.S.C. 306. 

27GAO, HUD and Treasury Programs: More Information on Leverage Measures’ Accuracy 

and Linkage to Program Goals Is Needed to Assessing Performance, GAO-08-136

(Washington, D.C.: Jan. 18, 2008); Tax Administration: IRS Needs to Further Refine Its 

Tax Filing Season Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002); 

and Executive Guide: Effectively Implementing the Government Performance and 

Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996). 

28GAO, Managing for Results: Analytic Challenges in Measuring Performance, 

GAO/HEHS/GGD-97-138 (Washington, D.C.: May 30, 1997). 

Page 20 GAO-09-796 Disaster Housing
 

further ensure that it is not the task itself being evaluated, but progress in 

achieving the intended outcome.29

Figure 9: Performance Measurement Model 

Department/Agency

mission, goals

Program mandate

and objectives

Government policies

and priorities

 Inputs Outputs

Goods and services

Other products

directed at external

clients

Client benefits

Program

consequences

Direct or indirect

effects or

consequences

Work tasks

Functions

Program

support

Dollars

Staff

Technology

Capital

 Outcomes Impact

Underlying

dimensions of

performance

measurement

Five

measurable

aspects of

performance

Policy and

program

context

Client reach

Client satisfaction

Social/Economic impacts

Contribution to objectives

Measures of

productivity/efficiency

Measures of effectiveness

Quantity (input/output ratios)

Quality (according to standards)

Cost (unit cost of output)

Budget variance

Resource utilization

 Activities

Source: Adapted from the Office of Management and Budget.

Measures of economy

 

29GAO, Military Operations: Actions Needed to Improve DOD’s Stability Operations 

Approach and Enhance Interagency Planning, GAO-07-549 (Washington, D.C.: May 31, 

2007). 

Page 21 GAO-09-796 Disaster Housing
 

FEMA’s performance measures for group sites are output measures that 

focus on the core program activity of closing group sites. But the measures 

do not provide the information on program results that is needed to assess 

the agency’s performance in achieving its goal of “helping individuals and 

communities affected by federally declared disasters return to normal 

functioning quickly and efficiently.”30 The Post-Katrina Act required that 

FEMA develop performance measures to help ensure that it provided 

timely and efficient housing assistance to individuals and households 

displaced by Hurricanes Katrina and Rita.31 In September 2007, FEMA 

began publicly reporting data on a weekly basis to provide information on 

the housing assistance that the agency provided, including at group sites. 

Specifically, FEMA reported general data on the aggregate number of 

households that moved out of travel trailers, park models, or mobile 

homes and into other types of FEMA housing assistance or that were no 

longer in FEMA’s program. However, these data do not provide 

information on whether households moved to permanent housing and are 

not reported by the specific type of site (e.g., group site). FEMA also 

reported data specific to group sites showing, for example, that FEMA 

provided temporary housing to 24,960 households, at one point, at these 

sites. These measures indicated that as of April 9, 2009, 577 households 

continued to live in group sites located in Louisiana and Mississippi.32

FEMA’s Performance 

Measures Focus on 

Program Activities at 

Group Sites, but Do Not 

Convey Information on 

Results 

These measures describe program outputs—that is, information on the 

number of sites established, current number of sites, number of 

households that lived in group sites, and current number of households—

but do not provide information on results, such as successfully moving 

households to permanent housing, or on qualitative factors, such as the 

timeliness or efficiency of the assistance FEMA provided at group sites. 

The difficulties experienced in closing group sites and transitioning 

households to permanent housing—as we have previously discussed—

 

30According to the Office of Management and Budget, output measures describe the level of 

a program’s activity, whereas outcome measures describe the intended result from carrying 

out a program or activity. 

31Pub. L. No. 109-295, section 638(e), 120 Stat. 1422 (2006). 

32On February 28, 2009, FEMA changed the format of its individual assistance weekly 

reports, which no longer include the total number of group sites established following 

Hurricanes Katrina and Rita and the current number of group sites still open. Prior to this 

date, FEMA also included data on industrial sites, private sites, and rental assistance. The 

last publicly available report on FEMA’s Web site was published on April 9, 2009. 

According to FEMA, 348 households continued to live in 101 group sites located in 

Louisiana and Mississippi, as of June 18, 2009. 

Page 22 GAO-09-796 Disaster Housing
 

underscore the need to develop measures that describe how efficiently 

and effectively the program is addressing its goal of “helping individuals 

and communities affected by federally declared disasters return to normal 

functioning quickly and efficiently.”33 For example, one potential measure 

could capture information on the amount of time households live in group 

sites before returning to permanent housing, and FEMA could establish a 

numerical target that facilitates the future assessment of whether its 

overall goal and objective were achieved. Having such information can 

help identify potential problems in meeting program goals and could be 

used to make management decisions about resources needed and steps to 

be taken. 

In its annual performance plans, FEMA also reports the percentage of 

customers that are satisfied with its disaster assistance programs. 

Although this measure may be a useful overall metric for assessing agency 

efforts on the quality of assistance provided to program beneficiaries, it is 

of limited use in assessing the agency performance in operating group 

sites because it is not reported separately for assistance provided through 

group sites. In the absence of other performance indicators to measure the 

efficiency or effectiveness and numeric targets, it is not possible to 

determine whether the disaster assistance programs are achieving the 

program goal of “helping individuals and communities affected by 

federally declared disasters return to normal functioning quickly and 

efficiently.” 

According to FEMA officials, the agency has not developed resultsoriented performance measures, in part, because of the uniqueness and 

unpredictable circumstances of each disaster. We recognize that the 

circumstances can vary significantly from one disaster to another, and that 

FEMA generally provides housing assistance in group sites as a last resort 

and following catastrophic disasters, such as Hurricanes Katrina and Rita. 

Nevertheless, FEMA could leverage its experiences and lessons learned 

from its responses to past major disasters to identify potential measures of 

the agency’s performance in closing group sites. Such measures could be 

modified as needed to reflect actual conditions and types of assistance 

deployed. In fact, FEMA has designed performance measures for other 

types of assistance that may vary from one disaster to another. 

Specifically, according to FEMA officials, the agency has developed some 

 

33Department of Homeland Security, Annual Performance Report for Fiscal Years 2008-

2010 (Washington, D.C.: May 7, 2009). 

Page 23 GAO-09-796 Disaster Housing
 

potential outcome measures for other activities (such as case management 

services). For example, FEMA reports on the number of households that 

have achieved their recovery plans and, therefore, no longer need case 

management. 

FEMA officials also told us that they recognized the importance of resultsbased measures and would like to develop them for measuring housing 

assistance provided at group sites. Furthermore, the National Disaster 

Housing Strategy recognizes that it is important to develop performance 

measures to achieve the agency’s national goals, and that feedback on 

performance will enable those involved in the national effort to assess 

progress, adopt best practices, and make course corrections.34

Nonetheless, FEMA has yet to specify whether and when it will develop 

outcome measures for group site assistance. Without performance 

measures that reflect program results and that are clearly linked to the 

agency’s goals, FEMA cannot demonstrate program results and progress in 

achieving intended policy objectives. Although not all disasters may 

require the use of group sites, future major disasters that involve 

protracted recovery efforts may have to rely on such sites to provide 

temporary housing. As the experience from the 2005 hurricanes show, 

there will be a strong demand for results-oriented measures on the part of 

Congress in fulfilling its oversight responsibilities and holding FEMA 

accountable for its performance. 

 

34Federal Emergency Management Agency, National Disaster Housing Strategy 

(Washington, D.C.: Jan. 16, 2009). 

Page 24 GAO-09-796 Disaster Housing
 

The Post-Katrina Act was enacted to address various shortcomings 

identified in the preparation for and response to Hurricane Katrina.35

Among other things, the Post-Katrina Act required the FEMA 

Administrator, in coordination with specified federal and nonfederal 

government agencies—including the American Red Cross, HUD, the 

National Advisory Council, and the National Council on Disability—to 

develop, coordinate, and maintain a national disaster housing strategy to 

help plan and protect the nation against future catastrophes. Among other 

things, FEMA was to outline the most efficient and cost-effective federal 

programs that will best meet the short- and long-term housing needs of 

individuals and households affected by a major disaster and describe plans 

for the operation of group sites provided to individuals and households. 

FEMA was to provide the strategy to Congress by July 1, 2007. On July 21, 

2008, FEMA released a draft strategy, with a 60-day comment period. 

However, the draft strategy did not include seven annexes that were to 

describe, among other things, the agency’s plans for operating group sites. 

Instead, the draft included seven blank pages of annexes marked “Under 

Development.”36

The Housing Strategy 

Defines FEMA’s Roles 

and Responsibilities 

for Closing Group 

Sites, but Does Not 

Have Key 

Characteristics of an 

Effective Strategy 

On January 16, 2009, FEMA released the final version of the National 

Disaster Housing Strategy, with annexes attached containing the 

information that had been omitted from the draft strategy. The strategy 

states that it serves two purposes—to describe how the nation currently 

provides housing to those affected by disasters and, more importantly, to 

chart a new direction that disaster housing efforts must take to better 

meet the emerging needs of disaster victims and communities. The 

strategy includes a discussion of key principles, roles and responsibilities, 

 

35The provisions of the Post-Katrina Act became effective upon enactment, October 4, 2006, 

with the exception of certain organizational changes related to FEMA, most of which took 

effect on March 31, 2007. 

36According to a 2008 report by the Senate Subcommittee on Disaster Recovery, the draft 

strategy violated two-thirds of its legal requirements and in doing so failed in the planning 

needed to protect the nation. For example, the draft strategy did not describe the disaster 

housing group site operations. See Senate Committee on Homeland Security and 

Governmental Affairs, Subcommittee on Disaster Recovery, FEMA’s Disaster Housing 

“Strategy:” Still Passing the Buck, Nearly Three Years After Katrina & Rita (Washington, 

D.C.: July 21, 2008). 

Page 25 GAO-09-796 Disaster Housing
 

current practices, and future directions for the three phases of disaster 

housing (sheltering, interim housing, and permanent housing).37

As we have previously mentioned, the Post-Katrina Act mandated that 

FEMA develop a disaster housing strategy, including plans for operating 

group sites. In earlier work, we identified certain key characteristics of 

effective national strategies and plans. For example, in 2007, we assessed 

the federal government’s preparedness to lead a response to an influenza 

pandemic and reported that effective national strategies and plans should 

contain certain key characteristics. Among these are38

• the agencies responsible for implementing the strategy or plan, the roles of 

the lead and supporting agencies, and mechanisms for coordination 

among the agencies; 

• the types of resources required—funding, staffing, and training—to 

effectively implement the strategy or plan and the means of acquiring 

these resources; and 

• the constraints and challenges involved in implementing the strategy or 

plan. 

The Disaster Housing Community Site Operations Annex, which is one of 

seven attachments of the National Disaster Housing Strategy, states that 

FEMA is responsible for closing group sites and assisting households in 

transitioning to permanent housing, but it did not fully address these key 

characteristics of an effective national strategy. 

 

37The disaster housing strategy defines “sheltering” as housing that provides short-term 

refuge and life-sustaining services for disaster victims who have been displaced from their 

homes and are unable to meet their own immediate postdisaster housing needs; “interim 

housing” as the intermediate period of housing assistance that covers the gap between 

sheltering and the return of disaster victims to permanent housing; and “permanent 

housing” as safe, sanitary, and secure housing that can be sustained without continued 

disaster-related assistance. 

38GAO, Influenza Pandemic: Further Efforts Are Needed to Ensure Clearer Federal 

Leadership Roles and an Effective National Strategy, GAO-07-781 (Washington, D.C.: 

Aug. 14, 2007). 

Page 26 GAO-09-796 Disaster Housing
 

We previously reported that a national strategy should address which 

organizations would implement the strategy, their roles and 

responsibilities, and mechanisms for coordinating their efforts. The 

strategy should answer the fundamental questions about who is in charge, 

not only during times of crisis, but also during all phases of emergency 

management, as well as the organizations that will provide the overall 

framework for accountability and oversight. This characteristic entails 

identifying the specific federal agencies and offices involved and, where 

appropriate, the different sectors, such as state, local, and private. 

The Strategy and 

Community Site 

Operations Annex Partially 

Address Roles and 

Responsibilities 

The National Disaster Housing Strategy’s Disaster Housing Community 

Site Operations Annex, which discusses the issue of closing group sites, 

partially addresses this characteristic. The annex contains information on 

FEMA’s roles and responsibilities for closing group sites and assisting 

households in transitioning to permanent housing.39 Specifically, it states 

that FEMA will assist with finding and matching rental resources to 

households living at these sites that were renting homes or apartments 

before the event and track the progress of repairs to damaged or destroyed 

homes owned by affected households. The annex also states that FEMA 

will provide access to local, state, and federal agencies that could help 

affected households with their unmet needs. 

However, the annex does not explain how other federal or state agencies 

will be involved in completing the tasks associated with transitioning a 

group site household to permanent housing and what mechanisms will be 

used to coordinate with these agencies in ensuring that victims can find a 

permanent housing unit. Furthermore, the annex does not reflect some of 

the experience that FEMA gained in responding to Hurricanes Katrina and 

Rita regarding coordinating with other agencies. For example, in response 

to widespread concerns about both the long periods that displaced 

 

39A community site is a site provided by the federal, state, or local government that 

accommodates two or more units and is connected to utilities. Before developing the 

current strategy, FEMA referred to these sites as group sites. In addition, the Disaster 

Housing Community Site Operations Annex of the National Disaster Housing Strategy 

includes information about all of the phases of establishing group sites, including 

(1) assessment of needs; (2) site selection; (3) site development; (4) placement of 

individuals and households; (5) site management; and (6) depopulation, conversion, and 

deactivation. We focused on the last phase of the process because our scope was on the 

closing of group sites and assisting households with transitioning to permanent housing. 

Furthermore, according to FEMA officials, the process of closing group sites and 

transitioning households into permanent housing that is described in the Disaster Housing 

Community Site Operations Annex is the same for commercial sites. 

Page 27 GAO-09-796 Disaster Housing
 

households were living in group sites and the health issues associated with 

the trailers on those sites, FEMA developed the 2007 FEMA Gulf Coast 

Recovery Office Housing Action Plan, which states that the agency would 

work with HUD to identify households that were receiving HUD assistance 

prior to the 2005 hurricanes. The plan also states that FEMA would 

transition the remaining households living in group sites into HUD’s 

Disaster Housing Assistance Program (DHAP), which is a pilot federal 

housing assistance grant program that provides temporary rental 

assistance through local public housing agencies that are experienced in 

administering other federal housing assistance.40 According to the 

National Disaster Housing Strategy, HUD’s and FEMA’s experience with 

DHAP demonstrates that rental assistance administered through HUD’s 

existing network of public housing agencies is an effective way to meet the 

long-term housing needs of displaced families following a disaster. 

Nonetheless, the National Disaster Housing Strategy does not specify 

HUD’s role in transitioning households out of group sites and into 

permanent housing. 

The Strategy and Annex 

Do Not Address Resources 

Required 

An effective national strategy should identify and describe the sources and 

types of resources required, such as funding, staff, and training, to 

effectively implement the strategy. Guidance on the costs and resources 

needed helps implementing parties allocate resources according to 

priorities, track cost, and shift resources, as appropriate, among other 

competing demands. Furthermore, the National Disaster Housing 

Strategy itself states that effective strategies identify the means or 

resources to achieve the strategies’ goals. However, we found that neither 

the strategy itself nor the Disaster Housing Community Site Operations 

Annex contained these elements. Specifically, the documents do not 

address the cost of helping households transition to permanent housing, 

the staffing resources that would be needed to complete this task, the type 

of training that should be provided to staff assigned to this task, and the 

sources (e.g., HUD; FEMA; or other federal, state, local, or private 

agencies) of the resources necessary to achieving FEMA’s goal of closing 

group sites and transitioning households into permanent housing. 

 

40In July 2007, FEMA and HUD entered into an interagency agreement to pilot DHAP, to 

temporarily extend rental assistance and case management services for victims displaced 

by Hurricanes Katrina and Rita. The program is funded by FEMA from the Disaster Relief 

Fund, which is the major source of federal disaster recovery assistance. 

Page 28 GAO-09-796 Disaster Housing
 

Again, the annex does not reflect some of the experience that FEMA 

gained in responding to Hurricanes Katrina and Rita. For example, in 

response to these hurricanes, FEMA’s Mississippi and Louisiana 

Transitional Recovery Offices developed housing plans that discussed 

some of the resources needed to assist households with transitioning out 

of group sites and into permanent housing.41 The Louisiana Transitional 

Recovery Office’s housing plan’s staffing strategy was designed to create a 

more effective labor force and labor mix to meet specific needs of the 

disasters, including mobilizing more experienced individuals with targeted 

functional skills sets. Similarly, the Mississippi Transitional Recovery 

Office’s housing plan provides information on the number of staff 

available to help households transition to permanent housing and states 

that no additional staff will be needed to complete this task. Furthermore, 

both of these plans emphasize the importance of providing training to their 

staffs to successfully assist affected households transition to permanent 

housing. In contrast, the National Disaster Housing Strategy does not 

identify and describe the resources needed, including staffing and training, 

to effectively transition group site households into permanent housing. 

The Strategy and Annex 

Do Not Address 

Constraints and 

Challenges 

Finally, an effective strategy should reflect a clear description and 

understanding of the problems to be addressed, their causes, and 

operating environment. A disaster housing strategy should discuss the 

constraints and challenges involved in closing group sites in the aftermath 

of a catastrophic incident, such as potential shortages in available 

permanent housing, and anticipate solutions to these challenges. However, 

the National Disaster Housing Strategy does not describe or anticipate 

challenges associated with helping people find permanent housing after a 

catastrophic event. In the past, FEMA has recognized the need to do so in 

order to help households move out of group sites. For example, FEMA’s 

November 2007 Gulf Coast Recovery Office Housing Action Plan described 

the specific challenges involved in closing the sites that were established 

after Hurricanes Katrina and Rita and the mechanisms available to address 

these challenges. For example, the plan states that households that have 

been living in group sites would be reluctant to move to unfurnished rental 

units, and that FEMA was to work with voluntary or other governmental 

agencies to provide furniture to the households. 

 

41FEMA, Louisiana Transitional Recovery Office, Louisiana Depopulation Implementation 

Plan (Nov. 6, 2007), and Mississippi Transitional Recovery Office, Mississippi 

Transitional Recovery Office Housing Action Plan (Nov. 28, 2007). 

Page 29 GAO-09-796 Disaster Housing
 

According to FEMA officials, the annex and strategy did not include the 

characteristics that we have previously discussed because these 

documents were meant to provide an overarching framework of FEMA’s 

process. Furthermore, officials said that it was difficult to outline the 

specific resources needed and the particular challenges FEMA could face 

in closing group sites and assisting households with the transition into 

permanent housing, mainly because each disaster presents unique needs 

and challenges. We previously identified the need for documents 

supporting a key strategy or plan, such as an annex, to contain detailed 

and robust information on how these plans are going to be implemented. 

For example, in February 2006, we reported that although the National 

Response Plan—which was revised in March 2008 and is now known as 

the National Response Framework—envisions a proactive national 

response in the event of a catastrophe, the nation did not yet have the 

types of detailed plans needed to better delineate capabilities that might 

be required and how such assistance will be provided and coordinated.42

We agree that no national strategy can anticipate and specify the precise 

resources and responsibilities appropriate for every circumstance. 

Nonetheless, this does not preclude FEMA from identifying the range of 

resources and responses appropriate for most circumstances. FEMA could 

leverage its experiences and lessons learned from responses to past major 

disasters in order to anticipate the types of challenges that could arise and 

the resources needed to address them. 

In 2007, we reported that the resources of certain federal agencies were 

not fully addressed in the National Response Plan, and that this hampered 

the ability of FEMA to provide leadership in coordinating and integrating 

overall federal efforts associated with housing assistance.43 The absence of 

detailed information in the housing strategy and its Disaster Housing 

Community Site Operations Annex on the partnerships that FEMA needs 

to form, the resources it needs, and the mechanisms that FEMA is to use 

to address the challenges specific to a catastrophic disaster when closing 

group sites and transitioning households to permanent housing can lead to 

delays in helping disaster victims return to more stable and conventional 

living arrangements. Lack of such plans may have contributed to the fact 

 

42GAO, Statement by Comptroller General David M. Walker on GAO’s Preliminary 

Observations Regarding Preparedness and Response to Hurricanes Katrina and Rita, 

GAO-06-365R (Washington, D.C.: Feb. 1, 2006). 

43GAO, Disaster Assistance: Better Planning Needed for Housing Victims of Catastrophic 

Disasters, GAO-07-88 (Washington, D.C.: Feb. 28, 2007). 

Page 30 GAO-09-796 Disaster Housing
 

that more than 3 years after Hurricanes Katrina and Rita, 348 households 

continued to live in group sites as of June 18, 2009.44

Although several temporary housing options could offer alternatives to 

travel trailers, FEMA’s National Disaster Housing Strategy does not 

identify alternatives to travel trailers or provide clear guidance on what 

other temporary housing options are available to states. In our discussions 

with officials and reports we reviewed, we identified various alternatives 

to travel trailers in group sites, many of which are already authorized 

under the emergency and temporary housing provisions of the Stafford 

Act that FEMA has used in recent disasters, including Hurricanes Katrina 

and Rita. FEMA’s National Disaster Housing Strategy does not assess 

alternatives to travel trailers because evaluations are ongoing, nor does it 

provide clear guidance on what other temporary housing options states 

should use instead of travel trailers while FEMA completes these 

assessments. Such assessments could be useful to states that are 

responsible for identifying and selecting temporary housing options after a 

major disaster. 

FEMA’s Strategy Does 

Not Identify 

Alternatives or 

Provide Clear 

Guidance on Using 

Currently Available 

Options 

Several Temporary 

Housing Options Could 

Offer Alternatives to Travel 

Trailers 

Alternatives to the use of travel trailers can be grouped into three broad 

categories of options, including (1) utilizing existing available housing, 

(2) repairing damaged rental housing, and (3) providing direct housing. 

Current FEMA programs utilize existing available housing through 

emergency and financial assistance under sections 403 and 408 of the 

Stafford Act. Under section 403, FEMA provides direct grants to state and 

local governments, which use the grants to provide emergency shelter to 

households displaced from their residences following major disasters. 

Emergency shelters can include hotels and apartment rentals. The Stafford 

Act does not impose specific time limits on section 403 assistance, and 

FEMA’s regulations generally restrict the amount of time to a maximum of 

6 months. Although the purposes of emergency sheltering and temporary 

Utilizing Existing Available 

Housing 

 

44As we have previously discussed, for the purposes of this report, our use of the term 

“group sites” includes both FEMA-constructed and preexisting commercial sites. 

Page 31 GAO-09-796 Disaster Housing
 

housing are different,45 according to several sources, when the availability 

of temporary housing options is limited, allowing households to remain in 

emergency shelters until they can move to more suitable temporary or 

permanent housing options may be preferable.46 Under section 408, FEMA 

has the authority to provide assistance for households to rent an 

apartment or other housing accommodations. 

Such assistance is also being provided through a pilot program modeled 

after HUD’s Housing Choice Voucher program, a rental subsidy program 

that serves more than 2 million low-income, elderly, and disabled 

households nationwide and is administered by local public housing 

agencies. In the summer of 2007, FEMA and HUD entered into an 

interagency agreement to pilot a federal housing assistance grant program, 

DHAP, to temporarily extend rental assistance for victims displaced by 

Hurricanes Katrina and Rita. The program is funded by FEMA, but is 

administered by selected public housing agencies that are currently 

administering a HUD-funded housing choice voucher program. In the fall 

of 2008, FEMA deployed a modified DHAP following Hurricanes Ike and 

Gustav. While DHAP is a pilot program, in the National Disaster Housing 

Strategy, FEMA recommended that Congress give HUD legislative 

authority to create a permanent DHAP-like program. According to the 

strategy, HUD’s and FEMA’s experience with the DHAP pilot 

demonstrated that rental assistance administered through HUD’s existing 

network of local public housing agencies is an effective way to meet the 

long-term housing needs of displaced families following a disaster. 

Citing HUD’s experience with rental assistance programs, some of the 

officials we contacted and reports we reviewed have found that temporary 

rental housing assistance should be modeled after HUD’s Housing Choice 

 

45Emergency sheltering provides immediate, short-term housing assistance for disaster 

victims who have been displaced from their homes, while temporary housing provides 

intermediate, longer-term housing assistance to cover the gap between emergency 

sheltering and the return to permanent housing. 

46A February 2009 report on deficiencies in federal disaster housing assistance after 

Hurricanes Katrina and Rita, recommended amending section 403 of the Stafford Act to 

permit extending the duration of section 403 emergency assistance in the event of a 

catastrophic disaster if FEMA determines that transition into section 408 assistance is not 

practicable or that such an extension is necessary to meet postcatastrophic housing needs. 

See Senate Committee on Homeland Security and Governmental Affairs, Ad Hoc 

Subcommittee on Disaster Recovery, Far From Home: Deficiencies in Federal Disaster 

Housing Assistance After Hurricanes Katrina and Rita and Recommendations for 

Improvement, S. Prt. No. 111-7, at 279 (2009). 

Page 32 GAO-09-796 Disaster Housing
 

Voucher program. In particular, several of these sources noted HUD’s 

experience with its voucher program in responding to disaster victims 

displaced by the 1996 Northridge Earthquake in Los Angeles, California. 

Vouchers allowed households displaced by this disaster to live in existing 

rental apartments of their choice. One report cited that if this specific 

temporary housing option had been deployed after the 2005 Gulf Coast 

hurricanes, FEMA could have deployed fewer travel trailers.47 The choice 

and mobility that the housing voucher program has to offer to disaster 

victims and the help that the victims receive in locating rental housing 

were the reasons generally cited by the sources for using this type of 

program for providing temporary housing after a major disaster. However, 

this option is not currently authorized under the Stafford Act provisions.48

Because of the limited number of rental units available following a major 

disaster and the amount of time required to construct new rental housing, 

a vital component of quickly bringing disaster victims back to the area is 

to repair damaged rental properties. Helping rental property owners 

quickly make repairs to existing properties could increase the number of 

available rental units.49 In past disasters, FEMA has been reluctant to be 

directly involved in the rapid repair of damaged rental housing, partly 

because the agency does not view housing construction as part of its core 

mission. However, the extent of destruction to the housing stock following 

the Katrina and Rita disasters highlighted the need to increase the 

availability of rental housing. As a result, the Post-Katrina Act established 

a pilot program authorizing FEMA to repair rental housing located in areas 

covered by a major disaster.50 The rental pilot, known as the Individuals 

and Households Pilot Program, permits FEMA to enter into lease 

Repairing Damaged Rental 

Housing 

 

47The Brookings Institution, Housing Families Displaced by Katrina: A Review of the 

Federal Response to Date (Washington, D.C.: Nov. 11, 2005). 

48The Emergency Supplemental Appropriations Act of 1994 was signed into law on 

February 12, 1994 (Pub. L. No. 103-211), and provided nearly $900 million in appropriations 

to HUD programs for communities impacted by disasters. Of this, $200 million was directed 

to provide Section 8 rental assistance to households displaced by the Northridge 

earthquake. 

49Under section 408 of the Stafford Act, FEMA also has the authority to provide financial 

assistance for the repair or replacement of owner occupied primary residences that 

sustained damage or were destroyed by a major disaster and FEMA can also provide 

assistance to construct permanent or semipermanent housing. We consider these forms of 

assistance as permanent housing options and do not include them in our discussion of 

available temporary housing options that can serve as alternatives to trailers in group sites. 

50Pub. L. No. 109-295, 689i, 120 Stat. 1454 (2006). 

Page 33 GAO-09-796 Disaster Housing
 

agreements with owners of multifamily rental properties and to repair 

damaged properties to meet federal housing quality standards. The 

repaired apartments are to be rented to displaced households for at least 

18 months (or longer, if necessary). 

In response to the midwest floods and Hurricane Ike, in September and 

December 2008, FEMA implemented pilots in Iowa and Texas, 

respectively. Specifically, FEMA selected apartments in Cedar Rapids, 

Iowa, and within this property funded the repair of seven two-bedroom 

units and in Galveston, Texas, funded the repair of 32 units. FEMA’s 

authority for the pilot program expired at the end of 2008. In accordance 

with the act, FEMA was to evaluate the effectiveness of the program and 

to report its findings to Congress at the end of March 2009, including any 

recommendations to continue the pilot program or to make the program a 

permanent housing option. In May 2009, FEMA issued a report on the pilot 

program, which stated that additional analysis and recommendations on 

whether to make the program permanent would be provided at a later 

date. Some officials we contacted and reports we reviewed mentioned that 

the federal government needs to do more to rapidly repair existing rental 

housing damaged during a major disaster to increase the rental stock 

available to disaster victims in the immediate area. An official from a 

nonprofit organization we contacted viewed the rapid repair of damaged 

rental units as an effective way to help households transition back to 

permanent housing more quickly, potentially reducing the need for longer 

stays in temporary housing options, such as travel trailers in group sites, 

which are not meant to be a long-term option. 

When rental housing is unavailable, FEMA has traditionally provided 

direct housing assistance to households displaced by major disasters, as it 

did after Hurricanes Katrina and Rita. Such assistance has included trailers 

and manufactured housing units that can be placed on homeowners’ 

property or on group sites. Travel trailers had been an important means of 

providing temporary housing after major disasters because the magnitude 

of these events limits the effectiveness of other options. FEMA can 

provide such assistance under section 408 of the Stafford Act and may also 

provide housing units owned or subsidized by other federal agencies, such 

as HUD and the Department of Veterans Affairs (VA), through agreements 

with these agencies. 

Providing Direct Housing 

Page 34 GAO-09-796 Disaster Housing
 

Travel trailers as direct housing assistance have been a standard part of 

FEMA’s recovery operations in disasters prior to the 2005 hurricanes and 

were intended for short-term use, but safety concerns involving the travel 

trailers used after the 2005 disasters led FEMA to change its policy.51 The 

agency’s 2008 disaster housing plan and the National Disaster Housing 

Strategy indicate that FEMA will no longer use group sites for the 

placement of travel trailers.52 Under current policies, FEMA will authorize 

the use of travel trailers only upon the request of the affected state when 

no other form of temporary housing is available. FEMA will also impose 

other restrictions on travel trailers, including that they be used only on 

private sites for no longer than 6 months and only after the state has 

determined that the trailers meet acceptable formaldehyde levels. In 2008, 

FEMA developed new performance specification requirements for all 

future temporary housing units purchased, including travel trailers, to 

eliminate the use of materials that emit formaldehyde.53 Finally, FEMA will 

continue to authorize group sites as a last resort for the placement of 

manufactured housing units. Although FEMA’s policy restricts trailers on 

group sites, several sources agreed that FEMA should use travel trailers or 

trailers on group sites as a last resort and only for a short period of time. 

Lots where these sites are located should be small and close to the 

displaced victims’ communities, with access to needed services. 

Utilizing government-owned or subsidized housing following a major 

disaster is another possible alternative, but this form of assistance tends to 

play a supportive role to other temporary housing options, since the 

number of units that could be utilized in a disaster tends to be relatively 

small. Under the Stafford Act, FEMA will enter into an agreement with 

other federal agencies, such as the U.S. Department of Agriculture, HUD, 

and VA, that own or subsidize property that could be used to provide 

temporary housing to disaster victims. For example, in response to 

Hurricane Katrina, about 10,000 federally owned or subsidized units were 

used to house disaster victims, including 5,600 HUD-owned single-family 

 

51In 2008, the Centers for Disease Control and Prevention identified the presence of 

significant levels of formaldehyde in the travel trailers in group sites that FEMA used 

following the 2005 hurricanes. Formaldehyde can pose serious health and safety concerns 

to those exposed to the chemical. 

52The strategy adopted an approach that was previously described in FEMA’s June 2008 

Disaster Housing Plan, which was in effect during the 2008 hurricane season when 

Hurricanes Gustav and Ike hit the Gulf Coast in September 2008. 

53FEMA Notice HQ-08-056, April 11, 2008: New FEMA Procurement Specifications Require 

Significantly Reduced Formaldehyde Levels In Mobile Homes And Park Models. 

Page 35 GAO-09-796 Disaster Housing
 

properties. According to FEMA, it encountered difficulties verifying that 

housing units offered by support agencies after Hurricane Katrina were 

indeed available for disaster victims. The National Disaster Housing 

Strategy indicates that since Katrina, the federal government has made 

some progress in cataloging available housing inventory through a number 

of online databases, potentially making it easier for FEMA to identify 

available units following a disaster. 

With Each Temporary 

Housing Option Involving 

Trade-offs, a Mix of 

Options Will Likely Be 

Needed to Respond to a 

Major Disaster 

Temporary housing options involve trade-offs that policymakers should 

consider in providing temporary housing assistance. The limitations 

involved in these trade-offs are magnified during a major disaster—for 

example, when much of the existing housing stock is severely damaged or 

destroyed and recovery efforts take years to complete. FEMA’s National 

Disaster Housing Strategy points to several key factors that should be 

considered when assessing the relative efficiency and effectiveness of 

temporary housing options, such as total cost and deployment time. We 

identified three key factors that we used to assess how trailers in group 

sites compared with possible alternative temporary housing options: cost, 

availability, and suitability. 

Cost involves the total cost to the government for purchasing, installing, 

maintaining, and (if applicable) deactivating the housing unit over the 

period of use. Based on information presented in a 2008 DHS OIG report, 

the average unit cost for trailers in group sites ranged from about $75,000 

to $84,000, depending on whether FEMA purchases units that have to be 

manufactured or units that already exist.54 Based on reports we reviewed, 

utilizing existing rental housing is generally considered to be a costeffective approach for providing housing assistance, and, according to 

FEMA, it is less costly when compared with trailers in group sites. The 

principal cost to the government of existing housing is the monthly rents, 

which, under the section 408 program, are based on the fair market rentlevel established by HUD. According to several sources, when compared 

with trailers, repairing damaged housing could cost less, and furthermore 

the benefits of repairs would be realized over a longer period of time. In a 

May 2009 report, FEMA estimated that completing rapid repairs and 

making monthly operating payments to two sites in Iowa and Texas were 

Cost 

 

54Department of Homeland Security, Office of Inspector General, FEMA’s Sheltering and 

Transitional Housing Activities After Hurricane Katrina, OIG-08-93 (Washington, D.C.: 

Sept. 12, 2008). 

Page 36 GAO-09-796 Disaster Housing
 

substantially less expensive than deploying and operating manufactured 

units over a similar period of time.55

Determining whether temporary housing options are available after a 

disaster occurs is a key consideration in assessing the viability of the 

options. Although utilizing existing housing is generally FEMA’s preferred 

way of providing temporary housing after a major disaster, there may not 

be sufficient housing available in the affected area to house displaced 

victims. At the same time, although disaster victims could be relocated to 

areas outside of the disaster area, FEMA officials said that victims 

generally prefer to remain near the affected area. Another obstacle that 

affects the availability of utilizing existing housing is the willingness of 

landlords to participate in the program. No information is available on the 

time required to repair damaged housing, and the current pilot program is 

not permanently authorized and may not be available in future disasters. If 

authorized, rental repair programs could potentially be deployed quickly, 

provided that funding was available and property owners were willing to 

participate. As we have previously stated, FEMA will no longer place 

travel trailers on group sites following a major disaster. However, the 

extent to which FEMA will still use travel trailers in other sites and the 

availability of trailers is unclear. Specifically, while the strategy and FEMA 

policy state that trailers will be used as a last resort when other temporary 

housing options are unavailable, a recent report by the Senate Ad Hoc 

Subcommittee on Disaster Recovery included an acknowledgment by 

FEMA officials that the agency will continue to use trailers in large 

numbers in responding to temporary housing needs following a 

catastrophic disaster.56 One FEMA official also acknowledged that the 

agency did not currently have sufficient housing resources to meet the 

demands of a large-scale event. Although FEMA awarded four contracts in 

April 2009 for the manufacture of low-emission travel trailers, the number 

of units contracted may not be sufficient to address housing needs after a 

major disaster, based on the number of units that were required in the Gulf 

Coast after the 2005 hurricanes.57

Availability

 

55Federal Emergency Management Agency, Individuals and Households Pilot Program: 

Fiscal Year 2009 Report to Congress (Washington, D.C.: May 19, 2009). FEMA estimated 

that rapid repair was about 83 percent less expensive than manufactured units in the Iowa 

pilot program and 66 percent less expensive than in the Texas pilot. 

56Far From Home: Deficiencies in Federal Disaster Housing Assistance. 

57The agency intends to order a minimum of 100 units from each contract award, with the 

ability to order 6,000 units each year for 5 years. 

Page 37 GAO-09-796 Disaster Housing
 

Temporary housing options must also meet the needs of affected 

households, including proximity to work and access to health and social 

services. Existing housing generally provides the households with a choice 

of housing units that meet their needs and generally allows for longer 

stays. Furthermore, as it does with the DHAP program, FEMA could use 

existing administrative networks (such as public housing agencies) to help 

find suitable housing. When sufficient existing housing is not available, 

rapid repair of damaged rental housing offers some of the same 

advantages of using existing housing, including the possibility of longer 

stays. In terms of suitability, trailers in group sites are the least-preferred 

option. Concerns about trailers in group sites after the 2005 hurricanes 

often focused on the long-term use of this option in sites that were isolated 

and lacked access to needed services.58 Although FEMA plans not to use 

trailers in group sites, several sources stated that these trailers are most 

suitable when they are used for a short period of time in proximity to the 

victims’ communities, allow for access to needed services, and do not pose 

health and safety risks to the occupants. 

Suitability

While the temporary housing options discussed in this report can serve as 

possible alternatives to travel trailers in group sites, several of the officials 

we contacted and reports we reviewed agreed that no single alternative 

was best suited to providing temporary housing after a major disaster. 

According to some of these sources, officials should consider a mix of 

housing options that are determined to be most efficient, effective, and 

specific to the circumstances of the disaster. 

FEMA’s Disaster Housing 

Strategy Neither Assesses 

Alternatives to Trailers Nor 

Provides Clear Guidance 

on What Options States 

Can Use Instead of Trailers 

FEMA’s National Disaster Housing Strategy does not assess alternatives 

to trailers because evaluations are ongoing, nor does it provide clear 

guidance on what other temporary housing options states should use 

instead of trailers while FEMA completes these assessments. Such 

assessments could be useful to states that are responsible for identifying 

and selecting temporary housing options after a major disaster. In 

accordance with the Post-Katrina Act and as part of the strategy, FEMA 

 

58In a related December 2008 GAO report on disaster assistance following Hurricanes 

Katrina and Rita, we reported that FEMA officials stated that given the level of destruction 

caused by these hurricanes and, in some cases, opposition from communities, FEMA was 

not always able to locate temporary housing in places with easy access to existing 

infrastructure, even though in instances where FEMA creates group sites, its guidance 

suggests that such sites should be located near existing supermarkets, public 

transportation, schools, and health care facilities. See GAO-09-81.

Page 38 GAO-09-796 Disaster Housing
 

was to identify the most efficient and cost-effective federal programs for 

meeting the short- and long-term housing needs of households affected by 

a major disaster. In describing these programs in the strategy, FEMA 

• identified currently available options for providing temporary housing 

after a major disaster under the housing assistance provision of FEMA’s 

section 408 program, such as rental assistance to disaster victims in 

existing privately owned rental properties and temporary housing units, 

such as mobile homes; 

• described a number of factors that were relevant in selecting and 

deploying temporary housing options, including relative costs, 

implementation time, and program funding levels; and 

• provided a broad framework of how states were to consider these factors 

in selecting specific temporary housing options—for example, FEMA 

characterized the section 408 rental assistance provision as more efficient 

as long as rental housing was available and the direct assistance provision 

as less efficient due to the time needed to activate units, such as mobile 

homes. 

The strategy describes ongoing initiatives that FEMA has undertaken since 

Hurricanes Katrina and Rita to identify alternative forms of temporary 

housing. These initiatives include the Alternative Housing Pilot Program 

(AHPP), which was created in 2006 to identify, implement, and evaluate 

disaster housing alternatives to travel trailers.59 According to FEMA 

officials, the evaluation process will continue through 2011, at which time 

FEMA will issue a final report to Congress. FEMA also established in 2006 

the Joint Housing Solutions Group (JHSG) to identify, among other things, 

viable alternatives to travel trailers and manufactured homes by working 

with manufacturers of these units.60 FEMA has not established an 

estimated completion date for this effort. 

 

59FEMA designed the AHPP as a competitive grant to the Gulf Coast States and awarded 

projects to the following four states: Alabama, Louisiana, Mississippi, and Texas. 

60In 2008, FEMA conducted a solicitation and awarded provisional contracts to seven 

alternative housing manufacturers. The JHSG has recently begun to assess and evaluate the 

viability of the units identified by these manufacturers on the basis of criteria such as cost, 

livability, and deployment time. According to FEMA, once the testing of pilot units is 

complete and the JHSG determines that the units meet safety, security, and affordability 

requirements, FEMA will begin purchasing units. 

Page 39 GAO-09-796 Disaster Housing
 

The strategy is unclear regarding when travel trailers could be used 

following a major disaster or what other temporary housing options states 

should use instead of trailers while FEMA completes its assessments. 

Specifically, the strategy indicates that travel trailers will continue to be 

used as a last resort; however, it does not describe the specific conditions 

where trailers would be a viable option or those situations where trailers 

should not be used. In addition, the strategy does not recommend an 

option (or options) that would replace trailers and would be deployable on 

the scale needed to respond to a major disaster while it considers 

alternatives to trailers. In its March 2008 report, DHS OIG also raised 

concerns about how FEMA plans to temporarily house disaster victims for 

future catastrophic events.61 According to the OIG, FEMA needs to 

develop and test new and innovative catastrophic disaster housing plans

to deal with the large-scale displacement of households for extended 

periods of time. In addition, in its February 2009 report on the federal 

government’s disaster housing response after Hurricanes Katrina and Rita, 

the Senate Ad Hoc Subcommittee on Disaster Recovery concluded that 

FEMA has not planned sufficiently to replace travel trailers. to 

r 

disasters. 

ers 

spended the 

ised 

 

62 According

the report, FEMA does not offer a substitute for mass trailers when othe

forms of temporary housing are unavailable, as can happen after major 

Not only did the January 2009 strategy not specify what other temporary 

housing options states should use instead of trailers, prior FEMA guidance 

also did not communicate clearly to states and others on the use of trail

in future disasters. Since Hurricanes Katrina and Rita, FEMA’s policies 

have been inconsistent regarding the use of travel trailers. For example, 

FEMA issued interim guidance in July 2007 that temporarily su

use of travel trailers while the agency worked with health and 

environmental experts to assess air quality and health-related concerns. 

On the basis of the preliminary results of this assessment, FEMA’s rev

guidance in March 2008 stated “it will not deploy travel trailers” as a 

temporary housing option. A month later, FEMA’s Administrator told 

61Department of Homeland Security, Office of Inspector General, FEMA’s Preparedness for 

the Next Catastrophic Disaster, OIG-08-34 (Washington, D.C.: March 2008). 

62See Far From Home: Deficiencies in Federal Disaster Housing Assistance. 

Furthermore, the report indicated that FEMA’s assessment on the efficiency and 

effectiveness of the options was “general” in nature, and suggested that FEMA should build 

on the information presented in the strategy and provide more specific cost-effectiveness 

studies of the available housing options so that policymakers and state and local 

governments can make informed decisions about which programs to use. 

Page 40 GAO-09-796 Disaster Housing
 

Congress that the agency was never going to use travel trailers again, yet 

2 months later FEMA changed its policy to allow limited use of travel 

trailers. According to that guidance issued in June 2008, trailers w

remain an option upon a state’s request in extraordinary disaster 

conditions when no other form of temporary housing is available. The 

guidance also indicated that FEMA would no longer enter into contra

for the manufacture of travel trailers. However, FEMA awarded four 

ould 

cts 

contracts in April 2009 for the manufacture of low-emission travel trailers. 

s 

e 

 the 

s 

s. 

tims 

s to travel trailers, were not yet available to the states for future 

disasters. 

t 

s in 

deciding on what forms of temporary housing assistance to deploy. 

Given all of the changes in guidance on the use of trailers since the Gulf 

Coast hurricanes, FEMA did not ensure the strategy clarified its policie

and provided sufficient details so that states understand the extent to 

which trailers (as well as other options) are available and practicable for 

future disasters. Officials from Texas and Louisiana with whom we spok

also agreed that the strategy did not clearly describe the circumstances 

under which temporary housing options could be used in responding to 

the needs of disaster victims and did not identify alternatives for options

that could not be used. Louisiana officials, for example, told us that

strategy provided a good overview on the categories of assistance 

available to states following a major disaster. However, these description

lacked information on the specific situation or circumstance that would 

“trigger” when a particular option could be used, according to the official

Furthermore, the officials noted that reference in the strategy regarding 

the options being currently available to meet the needs of disaster vic

was misleading for some of the options described. In particular, the 

officials did not believe that the use of innovative forms of temporary

housing should have been included as a current practice for housing 

disaster victims following major disasters because new options, including 

alternative

Without more specific information on interim alternatives to travel trailers

while FEMA continues to conduct its assessments, state officials will not 

have the information needed to choose those that would be most effective

and expedite decision making. As a result, FEMA and the states may no

be fully prepared to respond to the temporary housing needs of those 

displaced by major or even catastrophic events. The absence of clear 

guidance for state officials on the most appropriate housing options and 

the lack of specific options to replace travel trailers can lead to delay

Page 41 GAO-09-796 Disaster Housing
 

FEMA began reporting basic performance measures about closing group 

sites in the Gulf Coast region after the 2005 hurricanes, but these measures 

did not provide information on the effectiveness of the program in meeting 

its goals. As we have previously reported, it is important for federal 

agencies to identify performance measures that go beyond summarizing 

program activities. We have found that performance measures focused on 

results are most effective in assessing the achievement of policy 

objectives. FEMA officials agree that developing measures that focus on 

results is critical, and, with the establishment of the National Disaster 

Housing Strategy, FEMA will have an opportunity to develop such 

measures consistent with the strategy in future disasters. We recognize 

that each disaster presents its own unique set of challenges, but FEMA can 

leverage its experiences and lessons learned from its responses to past 

major disasters to identify a range of potential measures of the agency’s 

performance in closing group sites and assisting households with 

transitioning to permanent housing. Furthermore, the agency can modify 

such measures as needed to reflect the realities of future disasters. Having 

results-oriented measures, such as the amount of time that households live 

in group sites before returning to permanent housing, and developing 

numerical targets can help identify potential problems in meeting program 

goals and could be used to make decisions about resources needed and 

actions to be taken. Without measures that reflect program results and 

clearly link to the agency’s goals, FEMA will not be able to demonstrate 

program results and progress in achieving its intended objectives. 

Conclusions 

The completion of the National Disaster Housing Strategy and the 

Disaster Housing Community Site Operations Annex is an important step 

in the agency’s efforts to more clearly describe its roles and 

responsibilities for closing group sites and assisting households with the 

transition into permanent housing. However, these documents lack several 

key characteristics for an effective strategy and plan. As a result, their 

usefulness as a management tool for ensuring that FEMA meets its goal of 

helping households find safe and suitable permanent housing after a 

disaster is limited. For example, because the strategy and the annex do not 

address the roles and responsibilities of other federal and state agencies in 

closing group sites and transitioning households into permanent housing, 

stakeholders and the public may not have a full understanding of their role 

and responsibilities. Furthermore, because these documents did not 

address the resources to assist households living in group sites transition 

into permanent housing, it is unclear what resources are needed to build 

capacity and whether they would be available. Finally, because these 

documents did not describe or anticipate challenges associated with 

helping people find permanent housing after a catastrophic event, delays 

Page 42 GAO-09-796 Disaster Housing
 

could occur in helping disaster victims return to more stable and 

conventional living arrangements. Opportunities exist to improve the 

usefulness of these documents, especially the annex, because FEMA views 

them as evolving documents that are to be updated on a regular basis to 

reflect ongoing policy decisions. 

Historically, FEMA has relied on travel trailers to provide temporary 

housing to displaced households, especially after a major disaster when 

other temporary housing options (such as existing rental housing) are not 

sufficient. The use of these trailers has received significant criticism after 

the 2005 hurricanes due to safety and health issues as well as suitability 

for long-term use. While FEMA has changed its policy, it has made little 

progress in issuing or providing clear and consistent guidance on when 

travel trailers should be deployed following major disasters. Furthermore, 

while FEMA has initiated various assessments to identify potential 

temporary housing options that retain many of the conveniences of trailers 

but are safer and more suitable to the occupants, the lack of specific 

information on the interim alternatives to travel trailers will impede 

decision making by the states and places disaster victims at risk of not 

receiving temporary housing assistance as quickly as possible following a 

major disaster. 

To ensure that Congress and others have accurate information about the 

performance of Federal Emergency Management Agency’s direct housing 

assistance in group sites, we are making three recommendations to the 

Secretary of the Department of Homeland Security to direct FEMA to 

develop performance measures and targets that the agency will use for 

reporting on the results of closing group sites and assisting households 

with transitioning to permanent housing, and ensure that these measures 

are clearly linked with FEMA’s goals for disaster assistance. 

Recommendations for 

Executive Action 

In addition, because of the multiple agencies with which FEMA must 

coordinate in delivering temporary housing assistance, we recommend 

that the Secretary of Homeland Security direct FEMA to take the following 

actions: 

• Update its planning documents (e.g., the Disaster Housing Community Site 

Operations Annex of the National Disaster Housing Strategy) to describe 

how it will work with other agencies in closing group sites and 

transitioning households into permanent housing, what resources it needs 

Page 43 GAO-09-796 Disaster Housing
 

to perform these activities, and how it will deal with specific challenges of 

a major disaster, such as potential shortages in available permanent 

housing. 

• Describe clearly in its guidance to states how trailers or other options 

identified by the states can be deployed when other preferred housing 

options, such as existing rental housing, are not sufficient after a major 

disaster. 

We provided a draft of this report to the Department of Homeland 

Security’s Federal Emergency Management Agency for its review and 

comment. We received written comments from the Secretary of the 

Department of Homeland Security, which are reprinted in appendix II. The 

agency also provided a technical comment, which we incorporated into 

the report. 

Agency Comments 

and Our Evaluation 

FEMA generally agreed with our recommendations and is planning to take 

steps to address them. Specifically, FEMA intends to work through the 

National Disaster Housing Task Force to establish standard performance 

measures and reporting methods for all aspects of its direct assistance 

program, including group sites. FEMA also intends to work through the 

task force to address interagency operational issues. Although FEMA 

indicated that the strategy, including its annexes, will be updated as 

needed, it did not specifically discuss (1) whether these particular or other 

planning documents will describe how FEMA will work with other 

agencies in closing group sites and transitioning households into 

permanent housing; (2) what resources it needs to perform these 

activities; and (3) how it will deal with specific challenges of a major 

disaster, such as potential shortages in available permanent housing. We 

continue to believe that FEMA should update its planning documents to 

include these key characteristics of effective strategies and plans. Finally, 

FEMA said that the agency has been working to develop guidance for Joint 

Field Offices and the states on formally requesting and approving the use 

of temporary housing assistance programs following a disaster, including 

direct assistance. According to FEMA, the agency intends to clearly 

describe this process in the National Disaster Housing Concept of 

Operations. 

Page 44 GAO-09-796 Disaster Housing
 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

appropriate congressional committees, the Secretary of the Department of 

Homeland Security, and other interested parties. The report will also be 

available at no charge on the GAO Web site at http://www.gao.gov. 

If you or your staffs have any questions about this report, please contact 

me at (202) 512-8678 or sciremj@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

Mathew J. Scirè 

of this report. Key contributors to this report are listed in appendix III. 

Director, Financial Markets and 

 Community Investment Issues 

Page 45 GAO-09-796 Disaster Housing
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

The objectives of this report were to examine (1) challenges that 

households living in group sites faced in transitioning to permanent 

housing; (2) the extent to which the Federal Emergency Management 

Agency (FEMA) effectively measured its performance in closing group 

sites and assisting households with transitioning into permanent housing; 

(3) the National Disaster Housing Strategy’s effectiveness in defining 

FEMA’s roles and responsibilities for closing group sites and assisting 

households with transitioning to permanent housing; and (4) the 

alternatives to travel trailers in group sites when providing temporary 

housing after major disasters, how they compare with respect to identified 

policy factors, and how well FEMA’s National Disaster Housing Strategy

assessed these alternatives. Our review focused on FEMA’s programs for 

temporary housing in Alabama, Louisiana, Mississippi, and Texas, 

including the use of group sites in the aftermath of Hurricanes Katrina and 

Rita. For the purposes of this report, the term “group sites” refers to both 

sites established by FEMA and commercial sites that already existed and 

were used to house hurricane victims. 

For all four objectives, we interviewed officials from FEMA’s Disaster 

Assistance Directorate, Individual Assistance Branch, Office of Policy and 

Program Analysis, Office of the Federal Coordinator for Gulf Coast 

Rebuilding, Gulf Coast Recovery Office (GCRO), and Recovery Division. 

We also interviewed state officials from the Louisiana Recovery Authority, 

the Mississippi Governor’s Office of Recovery and Renewal, and the Texas 

Department of Housing and Community Affairs. 

To identify challenges that households living in group sites faced 

transitioning to permanent housing, we examined reports related to the 

federal government’s response to Hurricanes Katrina and Rita and its 

efforts to provide housing assistance in group sites. Specifically, we 

reviewed relevant reports, including reports from the Department of 

Homeland Security’s (DHS) Office of Inspector General (OIG), Louisiana 

Family Recovery Corps, The Brookings Institution, RAND Gulf States 

Policy Institution, PolicyLink, Congressional Research Service, and GAO. 

In addition to interviewing FEMA officials and officials from the state 

agencies that we have previously mentioned, we conducted site visits to 

Baton Rouge and New Orleans, Louisiana, where we met with officials 

from the following selected local housing agencies and not-for-profit 

organizations to obtain their perspectives on the challenges that 

households living in group sites faced: 

Page 46 GAO-09-796 Disaster Housing 
Appendix I: Scope and Methodology 

Page 47 GAO-09-796 Disaster Housing 

• Local agencies 

Jefferson Parish Housing Authority 

Housing Authority of East Baton Rouge 

Housing Authority of New Orleans 

Louisiana Housing Finance Agency 

New Orleans Office of Recovery and Development Administration 

• Not-for-profit organizations 

Louisiana Family Recovery Corp 

Catholic Charities 

Greater New Orleans Fair Housing Action Center 

Louisiana Justice Institute 

We also visited three group sites, including Renaissance Village—the 

largest group site established. To corroborate some of the challenges 

mentioned during our interviews, we analyzed several data sources. 

Specifically, to determine the extent to which Hurricanes Katrina and Rita 

had an impact on rents in these areas, we analyzed data from the 

Department of Housing and Urban Development (HUD) on the fair market 

rents for two-bedroom units in the Beaumont-Port Arthur, Texas, 

metropolitan statistical area (MSA); Gulfport-Biloxi, Mississippi, MSA; 

Mobile, Alabama, MSA, and New Orleans-Metairie-Kenner, Louisiana, 

MSA, from fiscal years 2005 to 2009. Furthermore, to determine the change 

in unemployment rates in the selected MSAs following Hurricanes Katrina 

and Rita, we analyzed annual unemployment rates data from the 

Department of Labor’s Bureau of Labor Statistics from fiscal years 2004 to 

2007. In addition, we collected and analyzed data from FEMA to determine 

the average reported income for households living in group sites in 

Louisiana and Mississippi. We focused on group sites in Louisiana and 

Mississippi for this analysis because FEMA established most sites in these 

states. Specifically, we obtained information from two of FEMA’s 

databases—the FEMA Response and Recovery Applicant Tracking System 

(FRRATS) and the National Emergency Management Information System 

(NEMIS). 

• FRRATS data are collected through FEMA field offices. Information 

obtained from FRRATS included receipts for the purchase of travel trailers 

and data on the type of site and the state where the trailer or mobile home 

was located. 
Appendix I: Scope and Methodology 

• NEMIS data are collected through the national FEMA office. Information 

obtained from NEMIS included date of birth, age, income of those 

receiving housing assistance, owner or renter status, and former and 

current addresses. 

• Both FRRATS and NEMIS contain a unique registration ID that we used to 

match the data we collected from these databases. 

We have tested the reliability of these data as part of a previous study and 

found the data to be reliable.1

 We determined that the data provided were 

sufficiently reliable for the purposes of this report. However, it is 

important to note that the demographic data in NEMIS are largely selfreported by applicants, and FEMA does not independently verify all of the 

data it collects. As an example, while some of FEMA’s assistance 

programs are based on income, the incomes reported in NEMIS are not 

verified. Our analysis was based on the highest income reported by an 

individual. Also, our analysis was limited to individuals who provided the 

information, and we did not determine whether nonrespondents were 

likely to differ from those who responded. 

To assess the extent to which FEMA effectively measured its performance 

in providing housing assistance in group sites, we reviewed FEMA’s 

strategic plan and DHS’s annual performance report and other documents 

related to the measures that FEMA developed to assess its performance. 

To identify the measures that FEMA developed to track the number of 

group sites it used after Hurricanes Katrina and Rita and the number of 

households that lived in those sites, we examined FEMA’s GCRO 

Individual Assistance Global Report Executive Summary weekly reports. 

We determined that these reports were sufficiently reliable for the 

purposes of our report. Finally, we assessed FEMA’s measures against 

criteria for effective performance measures described in our prior work.2

 

1

GAO, Disaster Assistance: Federal Efforts to Assist Group Site Residents with 

Employment, Services for Families with Children, and Transportation, GAO-09-81

(Washington, D.C.: Dec. 11, 2008). 

2

GAO, HUD and Treasury Programs: More Information on Leverage Measures’ Accuracy 

and Linkage to Program Goals Is Needed to Assessing Performance, GAO-08-136

(Washington, D.C.: Jan. 18, 2008); Tax Administration: IRS Needs to Further Refine Its 

Tax Filing Season Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002); 

and Executive Guide: Effectively Implementing the Government Performance and 

Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996). 

Page 48 GAO-09-796 Disaster Housing
Appendix I: Scope and Methodology 

To determine the National Disaster Housing Strategy’s effectiveness in 

defining FEMA’s roles and responsibilities for closing group sites and 

assisting households with transitioning to permanent housing, we 

reviewed the strategy and supporting annexes as well as federal 

emergency plans, including the National Response Framework and 

supporting annexes and the 2008 Disaster Housing Plan. Furthermore, we 

reviewed relevant sections of major statutes, regulations, and plans to 

better understand FEMA’s roles and responsibilities for closing group sites 

and assisting households with transitioning into permanent housing. 

Specifically, our review included the Robert T. Stafford Disaster Relief and 

Emergency Assistance Act of 1974 (Stafford Act)—as amended—and the 

Post-Katrina Emergency Management Reform Act (Post-Katrina Act). 

Additionally, we drew upon our extensive body of work on the federal 

government’s response to Hurricanes Katrina and Rita, as well as our prior 

work on pandemic influenza, to compare the relevant sections of the 

National Disaster Housing Strategy with the characteristics of an 

effective national strategy.3

 Specifically, we assessed the extent to which 

the strategy and the Disaster Housing Community Site Operations Annex 

addressed certain desirable characteristics and the related elements of 

these characteristics developed in previous GAO work.4

 Because we were 

not assessing the effectiveness of the entire National Disaster Housing 

Strategy and supporting annexes, we focused on three characteristics 

identified in previous work: organizational roles, responsibilities, and 

coordination; problem definition and risk assessment (i.e., challenges and 

constraints); and resources, investments, and risk management. Finally, 

we reviewed reports issued by Congress, DHS’s OIG, and the 

Congressional Research Service. 

To determine the alternatives to travel trailers in group sites and examine 

how they aligned with identified policy factors, we reviewed the Stafford 

Act, the Post-Katrina Act, and other related legislation. We also reviewed 

our previous reports and relevant literature, including reports from 

Congress, DHS’s OIG, and the Congressional Research Service and 

academic reports. In addition, we interviewed officials from FEMA, state 

 

3

For examples, see GAO, Influenza Pandemic: Further Efforts Are Needed to Ensure 

Clearer Federal Leadership Roles and an Effective National Strategy, GAO-07-781

(Washington, D.C.: Aug. 14, 2007); and Catastrophic Disasters: Enhanced Leadership, 

Capabilities, and Accountability Controls Will Improve the Effectiveness of the National 

Preparedness, Response, and Recovery System, GAO-06-618 (Washington, D.C.: Sept. 6, 

2006). 

4

GAO-07-781. 

Page 49 GAO-09-796 Disaster Housing
Appendix I: Scope and Methodology 

housing agencies in the Gulf Coast region, and selected nonprofit and 

housing research groups. We reviewed the National Disaster Housing 

Strategy to determine how well it assessed the capacity of available 

temporary housing options to respond to the housing needs of individuals 

displaced by a major disaster on the basis of certain factors, such as costeffectiveness and efficiency. We also interviewed officials from the 

previously mentioned state agencies to obtain their perspective on the 

extent to which FEMA provided sufficient information on the factors that 

should be considered when selecting an interim housing approach in 

response to a disaster. 

We conducted this performance audit from January 2008 through August 

2009 in Atlanta, Chicago, Louisiana, and Washington, D.C., in accordance 

with generally accepted government auditing standards. Those standards 

require that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our 

audit objectives. 

Page 50 GAO-09-796 Disaster Housing
Appendix II: Comments from the Department Appendix II: Comments from the Department of Homeland Security 

of Homeland Security 

Page 51 GAO-09-796 Disaster Housing 
Appendix II: Comments from the Department 

of Homeland Security 

Page 52 GAO-09-796 Disaster Housing
Appendix III: GAO

A

 Contact and 

cknowledgments 

Page 53 GAO-09-796 

Appendix III: GAO Contact and 

Acknowledgments 

Mathew J. Scirè, (202) 512-8678 or sciremj@gao.gov

In addition to the contact named above, Daniel Garcia-Diaz, Assistant 

Director; Emily Chalmers; Marshall Hamlett; John McGrail; Marc Molino; 

Josephine Perez; and Rose Schuville made key contributions to this report. 

 Disaster Housing 

GAO Contact 

Staff 

Acknowledgments 

(250375) 
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