Disaster Housing: FEMA Needs More Detailed Guidance and Performance Measures to Help Ensure Effective Assistance after Major Disasters
Published: 2009-08-28T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.

section_title: Letter
paragraphs: 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. 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  Hurricanes Katrina and Rita and future disasters. 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.  Specifically, this report examines (1) challenges that households living in  group sites faced in transitioning to permanent housing; (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  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.
subsections: section_title: Background
paragraphs: 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. FEMA administers the Stafford Act and provides direct  housing assistance (e.g., travel trailers and manufactured homes) under its  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.
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 long- term 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.
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).
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.
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.
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.
section_title: Households in FEMA Group Sites Have Faced Various Challenges in Returning to Permanent Housing
paragraphs: 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. 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. However,  according to some officials we contacted, households living in group sites  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.  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.
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.
subsections: section_title: Availability of Affordable Rental Housing Was a Key Challenge in Transitioning to Permanent Housing
paragraphs: 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 Gulfport- Biloxi 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. 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.
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  renters and homeowners who needed temporary rental units in the area  while their homes were being repaired.
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.
subsections: section_title: Limitations in Developing Affordable Rental Housing with Federal Subsidies
paragraphs: 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). 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.
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  credits were in service as of April 2008. 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. 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. 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,  including public and HUD-assisted housing. 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.
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.
section_title: Community Resistance to the Development of Affordable Housing
paragraphs: 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  rental housing units that it had planned to restore under the LIHTC  program.
section_title: Rebuilding Costs, Escalating Insurance Premiums, and Unemployment Also Affected Disaster Victims’ Efforts to Return to Permanent Housing
paragraphs: 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. 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. The DHS OIG report also found that high  construction costs, competition for available contractors, and new disaster  mitigation requirements compounded these financial problems.  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  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. 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 pre- Katrina 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.
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. 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. Most of those respondents not looking for  employment said they were disabled or had major health limitations.
section_title: FEMA Reports Basic Activities in Closing Group Sites, but Efforts to Measure Results Are Limited
paragraphs: 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. 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. 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 self- sufficiency among clients served).  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  further ensure that it is not the task itself being evaluated, but progress in  achieving the intended outcome.
subsections: section_title: FEMA’s Performance Measures Focus on Program Activities at Group Sites, but Do Not Convey Information on Results
paragraphs: 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.” 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. 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.
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— 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.” 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 results- oriented 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  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 results- based 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.  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.
section_title: The Housing Strategy Defines FEMA’s Roles and Responsibilities for Closing Group Sites, but Does Not Have Key Characteristics of an Effective Strategy
paragraphs: The Post-Katrina Act was enacted to address various shortcomings  identified in the preparation for and response to Hurricane Katrina.  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.”
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,  current practices, and future directions for the three phases of disaster  housing (sheltering, interim housing, and permanent housing).
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 are  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.
subsections: section_title: The Strategy and Community Site Operations Annex Partially Address Roles and Responsibilities
paragraphs: 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 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. 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  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. 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.
section_title: The Strategy and Annex Do Not Address Resources Required
paragraphs: 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.
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. 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.
section_title: The Strategy and Annex Do Not Address Constraints and Challenges
paragraphs: 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.
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.  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. 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  that more than 3 years after Hurricanes Katrina and Rita, 348 households  continued to live in group sites as of June 18, 2009.
section_title: FEMA’s Strategy Does Not Identify Alternatives or Provide Clear Guidance on Using Currently Available Options
paragraphs: 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.
subsections: section_title: Several Temporary Housing Options Could Offer Alternatives to Travel Trailers
paragraphs: 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.
subsections: section_title: Utilizing Existing Available Housing
paragraphs: 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  housing are different, 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. 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  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. 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.
section_title: Repairing Damaged Rental Housing
paragraphs: 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. 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. The rental pilot, known as the Individuals  and Households Pilot Program, permits FEMA to enter into lease  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.
section_title: Providing Direct Housing
paragraphs: 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.
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. 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. 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. 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  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.
section_title: With Each Temporary Housing Option Involving Trade-offs, a Mix of Options Will Likely Be Needed to Respond to a Major Disaster
paragraphs: 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.
subsections: section_title: Cost
paragraphs: 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. Based on reports we reviewed,  utilizing existing rental housing is generally considered to be a cost- effective 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 rent- level 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  substantially less expensive than deploying and operating manufactured  units over a similar period of time.
section_title: Availability
paragraphs: 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. 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.
section_title: Suitability
paragraphs: 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. 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.
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.
section_title: FEMA’s Disaster Housing Strategy Neither Assesses Alternatives to Trailers Nor Provides Clear Guidance on What Options States Can Use Instead of Trailers
paragraphs: 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  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. 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. FEMA has not established an  estimated completion date for this effort.
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. 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   According FEMA has not planned sufficiently to replace travel trailers. the report, FEMA does not offer a substitute for mass trailers when othe forms of temporary housing are unavailable, as can happen after major  disasters.
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 ers  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  ised  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 would  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 contracts  for the manufacture of travel trailers. However, FEMA awarded four  contracts in April 2009 for the manufacture of low-emission travel trailers.
Given all of the changes in guidance on the use of trailers since the Gulf  s  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 disasters.
section_title: Conclusions
paragraphs: 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.
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  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.
section_title: Recommendations for Executive Action
paragraphs: 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.
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  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.
section_title: Agency Comments and Our Evaluation
paragraphs: 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.
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.
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  of this report. Key contributors to this report are listed in appendix III.
section_title: Appendix I: Scope and Methodology
paragraphs: 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:  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 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.
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. 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 self- reported 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.
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. 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. 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  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 cost- effectiveness 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.
section_title: Appendix II: Comments from the Department of Homeland Security
section_title: Appendix III: GAO Contact and Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: 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.