Hurricane Sandy: An Investment Strategy Could Help the Federal Government Enhance National Resilience for Future Disasters
Published: 2015-07-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Disaster Relief Appropriations Act of 2013 appropriated about $50 billion for recovery from Hurricane Sandy, part of which was intended for disaster resilience and hazard mitigation. In March 2015, GAO identified the cost of disasters as a key source of federal fiscal exposure. GAO and others have advocated hazard mitigation to help limit the nation's fiscal exposure.
GAO was asked to review federal efforts to strengthen disaster resilience during Hurricane Sandy recovery. This report addresses (1) how federal recovery funds were used to enhance resilience, (2) the extent to which states and localities were able to maximize federal funding to enhance resilience; and (3) actions that could enhance resilience for future disasters.
To conduct this work, GAO reviewed key federal documents such as the National Mitigation Framework , interviewed federal officials responsible for programs that fund disaster resilience, and administered structured interviews and surveys to all 12 states, the District of Columbia, and New York City in the Sandy affected-region.
section_title: What GAO Found
paragraphs: During the Hurricane Sandy Recovery, five federal programs—the Federal Emergency Management Agency's (FEMA) Public Assistance (PA), Hazard Mitigation Grant Program (HMGP), the Federal Transit Administration's Public Transportation Emergency Relief Program, the Department of Housing and Urban Development's Community Development Block Grant-Disaster Recovery, and the U.S. Army Corps of Engineers' Hurricane Sandy program—helped enhance disaster resilience—the ability to prepare and plan for, absorb, recover from, and more successfully adapt to disasters. These programs funded a number of disaster-resilience measures, for example, acquiring and demolishing at-risk properties, elevating flood-prone structures, and erecting physical flood barriers.
State and local officials from the states affected by Hurricane Sandy GAO contacted reported that they were able to effectively leverage federal programs to enhance disaster resilience, but also experienced challenges that could result in missed opportunities. The challenges fell into three categories:
implementation challenges with PA and HMGP—for example, officials reported that FEMA officials did not always help them pursue opportunities to incorporate mitigation into permanent construction recovery projects;
limitations on comprehensive risk reduction approaches in a postdisaster environment—for example, officials reported difficulties with navigating multiple funding streams and various regulations of the different federal programs funded after Hurricane Sandy; and
local ability and willingness to participate—for example, officials reported that some home and business owners were unwilling or unable to bear the required personal cost share for a home-elevation or other mitigation project.
FEMA officials told us that they were aware of some of these challenges and recognize the need to further assess them. Assessing the challenges and taking corrective actions, as needed, could help enhance disaster resilience.
There is no comprehensive, strategic approach to identifying, prioritizing and implementing investments for disaster resilience, which increases the risk that the federal government and nonfederal partners will experience lower returns on investments or lost opportunities to strengthen key critical infrastructure and lifelines. Most federal funding for hazard mitigation is available after a disaster. For example, from fiscal years 2011-2014, FEMA obligated more than $3.2 billion for HMGP postdisaster hazard mitigation while the Pre-Disaster Mitigation Grant Program obligated approximately $222 million. There are benefits to investing in resilience postdisaster. Individuals and communities affected by a disaster may be more likely to invest their own resources while recovering. However, there are also challenges. Specifically, the emphasis on the postdisaster environment can create a reactionary and fragmented approach where disasters determine when and for what purpose the federal government invests in disaster resilience. The Mitigation Framework Leadership Group (MitFLG) was created to help coordinate hazard mitigation efforts of relevant local, state, tribal, and federal organizations. A comprehensive investment strategy, coordinated by MitFLG, could help address some challenges state and local officials experienced.
section_title: What GAO Recommends
paragraphs: GAO recommends that (1) FEMA assess the challenges state and local officials reported and implement corrective actions as needed and (2) MitFLG establish an investment strategy to identify, prioritize, and implement federal investments in disaster resilience. The Department of Homeland Security agreed with both.

section_title: Letter
paragraphs: In late October 2012, Hurricane Sandy devastated portions of the Mid- Atlantic and northeastern United States. As a result, more than 650,000  homes were damaged or destroyed, and hundreds of thousands of  businesses were damaged or forced to close at least temporarily.  On  January 29, 2013, the President signed the Disaster Relief Appropriations  Act, 2013 (Sandy Supplemental), which appropriated about $50 billion in  funding to support recovery across 19 federal agencies.
As we reported in December 2014, from fiscal years 2004 through 2013,  the Federal Emergency Management Agency (FEMA) obligated over $95  billion in federal disaster assistance for 650 major disasters declared  during this time frame. In 2014, the United States Global Change Research Program reported that the impacts and costliness of weather  disasters—resulting from floods, drought, and other events—will increase  in significance as what are considered rare events become more common  and intense because of climate change.In addition, less acute effects of  changes in the climate, such as sea level rise, could also result in  significant long-term effects on people and property. We have recognized  the rise in the number—and the increase in severity—of disasters as a  key source of federal fiscal exposure. Similarly, managing fiscal  exposure due to climate change has been on our high risk list since 2013,  in part, because of concerns about the increasing costs of disaster  response and recovery efforts. We and others have recommended  building disaster resilience—by taking actions to mitigate vulnerabilities to  the effects of severe weather and to adapt to effects of climate change— as one strategy to help to limit the nation’s fiscal exposure.
You expressed interest in whether and how federal funds used to help the  region affected by Hurricane Sandy are contributing to the recovery  process and enhancing disaster resilience to help reduce the potential for  future losses. This report addresses the following questions:   1.   How have states and localities in the Sandy-affected area used  federal funds to help enhance resilience during disaster recovery?   2.   To what extent did state officials report being able to use federal  programs to maximize resilience-building during disaster recovery?   3.   What actions did the federal government take to promote disaster  resilience in the recovery effort, and what, if any, improvements could  be made for future large-scale disasters?
To address our first objective, we reviewed program documentation— such as grant guidance and federal rules—and discussed program  purposes with key agency officials to determine whether and how  administered programs and activities facilitate community and regional  disaster resilience as part of rebuilding. We obtained information on  appropriations from the Sandy Supplemental and information related to  the purposes of programs and activities from the Sandy Supplemental  and federal agency documents. We focused on describing five federal  programs that have the ability to support disaster resilience-building  efforts that are administered by four federal agencies that received 92  percent of the Sandy Supplemental. We collected and analyzed  information from the District of Columbia, New York City, and each of the  12 states that had a major disaster declaration about the types of projects  for which they used federal funds to enhance disaster resilience as part of  the Hurricane Sandy recovery effort. We also reviewed state hazard  mitigation plans and local hazard mitigation plans and guidance. In  addition we reviewed information about large-scale state projects  provided by FEMA headquarters, FEMA’s Sandy Recovery Office and  state officials. During a site visit to New Jersey, 1 of the 2 states that  sustained the most damage, we also toured damaged areas and projects  in progress to observe and discuss planned resilience-building efforts.
We requested that State Hazard Mitigation Officers, in coordination with other  knowledgeable state officials, identify the federal and state funding streams that were  available for hazard mitigation projects and those that were used for projects during the  Sandy recovery. We also requested a comprehensive list or selected examples of hazard  mitigation projects their states had planned or underway. Additionally, we asked officials to  discuss their opinions of the successes and challenges of FEMA’s Public Assistance and  Hazard Mitigation Grant Program, the Department of Housing and Urban Development’s  (HUD) Community Development Block Grant- Disaster Recovery program, and the  Department of Transportation’s (DOT) Public Transportation Emergency Relief Program.
Hazard Mitigation Officers were joined by their state counterparts or  supervisors in state emergency management departments with  responsibility for managing other aspects of recovery efforts.  We also  administered the structured interview and survey to New York City’s  Office of Recovery and Resiliency, which administers some streams of  federal funds and oversees strategic planning for disaster resilience  efforts. In addition, we interviewed the New York Governor’s Office of  Storm Recovery, which is largely responsible for administering certain  non-FEMA federal funds and the New Jersey Governor’s Office of  Recovery and Rebuilding, which coordinates the state’s recovery effort,  including overseeing disaster resilience priorities. In New York and New  Jersey, the governors’ offices collaborated with the state emergency  management offices (particularly the State Hazard Mitigation Officers) to  complete the survey.
We compared information we learned from interviews with federal, state,  and local officials and from federal documents with the goals stated in the  National Disaster Recovery Framework (NDRF) and National Mitigation  Framework (NMF). Specifically, these policies call for the government to  integrate hazard mitigation and risk reduction opportunities into all major  decisions and reinvestments during the recovery process and to  capitalize on opportunities during the recovery building process to further  reduce vulnerability. In this respect, we considered the extent to which the  reported experiences of the state and local officials using these federal  programs were consistent governmentwide and reflected agency  management priorities for disaster resilience. The documentation and  information requests, structured interviews, and follow-up surveys were  administered in a selected group of states and are not generalizable to  the nation as a whole. However, they represent the entire population of  states involved in the recovery from Hurricane Sandy. The states span 4  of 10 FEMA regions and multiple geographic regions of the eastern  United States. In interviews and the follow-up survey, we discussed the  Hurricane Sandy recovery effort, as well as recovery from smaller  disasters that occurred since 2011. Accordingly, the results of the  interviews and surveys offer insights into the recent experiences  nonfederal users have building resilience during disaster recovery. The  overall response rate for the surveys was 92 percent.
To address our third objective, we reviewed federal statutes, regulations,  executive orders, and studies related to hazard mitigation and disaster  resilience. These included the Disaster Relief Appropriations Act of 2013  (Sandy Supplemental), the Sandy Recovery Improvement Act of 2013  (SRIA), the President’s Executive Order (EO) 13632—Establishing the  Hurricane Sandy Rebuilding Task Force, and the 2013 Hurricane Sandy  Rebuilding Strategy: Stronger Communities, A Resilient Region. We also  analyzed the recommendations of the Hurricane Sandy Task Force report  that were intended to help facilitate or remove obstacles to disaster  resilience. We obtained information about the status of implementing the  recommendations in the task force report from FEMA, the Department of  Housing and Urban Development (HUD) and the Department of  Transportation (DOT) and U.S. Army Corps of Engineers (USACE) via  documents and interviews with officials involved in the Hurricane Sandy  recovery. In addition, we obtained information on the status of  implementing disaster resilience-building related provisions of SRIA from  FEMA officials. We interviewed officials representing HUD, FEMA, and  the interdepartmental Mitigation Framework Leadership Group (MitFLG)  to discuss the challenges state officials reported to us and challenges  experienced at the federal level. As evidenced by the various recipients  of federal appropriations in the Sandy Supplemental, both disaster  recovery and building disaster resilience to reduce the federal fiscal  exposure to future disaster losses are missions that cut across federal  departments. Therefore, we compared the challenges reported by state  and federal officials to elements of a national strategy that we have  previously recommended to help support such efforts.
We conducted this performance audit from November 2013 to July 2015  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. For further information on our  objectives, scope, and methodology, see appendix I.
subsections: section_title: Background
subsections: section_title: Resilience, Mitigation, and Related Concepts
paragraphs: As shown in figure 1, resilience is a concept that has gained increasing  attention for its potential to decrease disaster losses.
section_title: Federal Roles, Responsibilities, and Doctrine for Promoting Disaster Resilience
paragraphs: FEMA, a component of the Department of Homeland Security (DHS),  leads the federal effort to mitigate, respond to, and recover from  disasters, both natural and man-made. Major disaster declarations can  trigger a variety of federal response and recovery programs for  government and nongovernmental entities, households, and individuals,  including hazard mitigation programs intended to increase the nation’s  disaster resilience.
However, multiple federal agencies can play a role in rebuilding after a  major disaster. For example, 19 agencies were appropriated funds for  more than 60 programs for Hurricane Sandy recovery in the Sandy  Supplemental, some of which provide opportunities to incorporate hazard  mitigation and other disaster resilience-building activities into disaster  recovery efforts. These programs include the (1) FEMA Hazard Mitigation  Grant Program (HMGP), (2) FEMA Public Assistance (PA), (3) HUD  Community Development Block Grant-Disaster Recovery (CDBG-DR), (4)  the Department of Transportation’s Federal Transit Administration (FTA)  Emergency Relief Program (ERP), and (5) USACE’s Sandy Program.  See table 1 for a description of these key programs and how they help to  support disaster resilience-building efforts.
Because FEMA is the lead federal agency for emergency management,  FEMA’s national-level strategies for recovery and hazard mitigation also  highlight the importance of incorporating hazard mitigation and other  disaster resilience activities into the recovery process. FEMA’s  September 2011 NDRF recognizes resilient rebuilding as one of the keys  to recovery success, stating that recovery is an opportunity for  communities to rebuild in a manner that reduces or eliminates risk from  future disasters.hazard mitigation breaks the cycle of damage-repair-damage resulting  from rebuilding without hazard mitigation measures following disasters.
Similarly, FEMA’s NMF states that linking recovery and  The NMF issued in May 2013 addresses, in part, how the nation will  develop, employ, and coordinate core hazard mitigation capabilities to  reduce loss of life and property by lessening the impact of disasters. The  NMF explains that building widespread disaster resilience throughout  communities is a national priority and is a responsibility that is shared by  individuals; businesses; non-profit organizations; and federal, state, local,  tribal, and territorial governments. The NMF also established MitFLG to  help coordinate hazard mitigation efforts of relevant local, state, tribal,  and federal organizations. MitFLG is an intergovernmental coordinating  body that was created to integrate federal efforts and promote a national  culture shift that incorporates risk management and hazard mitigation in  all planning, decision making, and development to the extent practicable.  Although federal agencies play a critical role in promoting disaster  resilience through the use of federal resources, a large part of disaster  resilience-building efforts and decision-making also occurs at the state  and local level. State and local laws and regulations can heavily influence  disaster resilience efforts, for example, by strengthening building codes.  In addition, state emergency management officials, such as State Hazard  Mitigation Officers, play an important role by coordinating with local  communities to enhance disaster resilience.
section_title: States and Localities Have Used Federal Funds to Help Plan and Implement Hazard Mitigation Projects to Enhance Resilience
paragraphs: States and localities have used funds appropriated to federal agencies by  the Sandy Supplemental to plan and implement a variety of hazard  mitigation activities, including but not limited to the following types of  projects: acquiring and demolishing properties at risk for repeated flooding, elevating flood prone structures, erecting physical flood barriers such as seawalls and berms to protect protecting critical facilities against power loss.   against coastal flooding,  restoring or enhancing storm water management measures,  restoring wetlands and coastal areas to control erosion, and   Four federal agencies—DHS’s FEMA, HUD, DOT’s FTA, and USACE— administer five programs that funded the majority of these disaster  resilience-building measures during the Hurricane Sandy recovery effort.  These five programs are FEMA’s Hazard Mitigation Grant Program,  FEMA’s Public Assistance, HUD’s Community Development Block Grant- Disaster Recovery, FTA’s Public Transportation Emergency Relief  Program, and USACE’s Sandy Program.
subsections: section_title: Hazard Mitigation Grant Program Funds Helped Sandy-Affected States Plan and Implement Hazard Mitigation to Enhance Disaster Resilience
paragraphs: Designed specifically to ensure opportunities to reduce the risk of loss of  life and property from future disasters are not lost during the  reconstruction process, HMGP can fund a variety of long-term solutions,  including but not limited to acquisition and demolition; elevation; and  retrofitting to minimize damages from high winds, earthquake, flood,  wildfire, or other natural hazards. FEMA requires that HMGP projects (1)  advance the state's Hazard Mitigation Plan; (2) meet the environmental  and historical requirements; and (3) be cost-effective, as determined by  FEMA’s Benefit-Cost Analysis Tool or other FEMA-approved  methodologies. In addition, HMGP projects must contribute to a long-term  solution, meaning that temporary measures—such as sandbagging to  protect against flooding—are not eligible.
FEMA awards HMGP after a major disaster has been declared, and the  total available amount for any given disaster is dependent on the sum of  other FEMA disaster grants—generally it is 15 percent of the first $2  billion but may be higher under specific circumstances.notifies the states of how much funding they are eligible to receive, and  the states working with FEMA then decide how to award the funds to  localities and other applicants. Recipients of HMGP are usually  responsible for 25 percent of the total project cost. HMGP may be used  statewide—that is, it is not required to be used only in parts of the state  that sustained disaster damage—as long as the state and local recipient  of funds has a FEMA-approved hazard mitigation plan in place.
As of May 2015, FEMA has awarded over $1.7 billion in HMGP funds  from the Sandy Supplemental for damage from Hurricane Sandy. State  officials we interviewed in all 13 Sandy-affected states reported using the  HMGP they received as a result of Hurricane Sandy to enhance disaster  resilience. These funds are being used for acquisition and demolition,  home elevations, or the purchase of generators to protect critical facilities  from future power loss, among other reasons. Figure 2 provides an  example of how one state in the Sandy-affected area used HMGP funds  to elevate homes.
section_title: Public Assistance Funds Have Helped to Restore Damaged Infrastructure while Enhancing Resilience to Future Damage
paragraphs: The Public Assistance program provides grants to states, local  governments, federally recognized Indian tribes, and certain private non- profit entities to assist them with the response to and recovery from  disasters. Specifically, the program provides assistance for debris  removal, emergency protective measures, and permanent restoration of  infrastructure, including funding hazard mitigation measures to reduce  future risks in conjunction with repair of disaster- damaged facilities  (under Stafford Act section 406) if cost-effectiveness can be  demonstrated.  The federal share of assistance is not less than 75  percent of the eligible cost for debris removal, emergency protective  measures, and permanent restoration. The state grantee determines how  the non-federal share (up to 25 percent) is split between the state and  eligible applicants. There is no pre-set limit to the amount of Public  Assistance funds a community may receive; however, Public Assistance  hazard mitigation measures must be determined to be cost-effective. In  addition, Public Assistance may fund measures that are not classified as  “hazard mitigation measures” but nevertheless serve to prevent or reduce  future damage. For example, in one state, Public Assistance was used to  replace boat docks that had been damaged by Sandy with floating docks  instead of the stationary docks that had previously been in place.  Although this activity was not classified as hazard mitigation under Public  Assistance guidelines, the state official expected the floating docks to be  more resilient than stationary docks during future disasters.
Sometimes, a combination of Public Assistance and HMGP funding may  be appropriate. That is, Public Assistance hazard mitigation funding may  be used to enhance the resilience of parts of the facility that were  damaged and HMGP funding may be used to provide future protection to  the undamaged parts of the facility.
States can also receive funds through the Public Assistance program  Alternative Procedures, under the authority of Stafford Act section 428,  which provides flexibility and financial incentives, some of which can be  used to enhance disaster resilience. For example, applicants using the  Alternative Procedures Program may choose to combine multiple critical  facilities of a state, tribal, or local government that were damaged by a  disaster and rebuild them in a manner that makes them less likely to incur  future disaster damages. For example, a community that had a fire and  police station destroyed could combine the facilities, rebuild them in an  area less prone to be affected by a future disaster, and enhance the  construction of the facility to meet up-to-date building codes.
As of March 2015, FEMA has awarded over $1.8 billion in total Public  Assistance permanent work funds to the 13 Sandy-affected states, of  which $400.6 million (22 percent) was approved to fund hazard mitigation  activities. FEMA data shows that 11 of the 13 Sandy-affected states used  PA funding for mitigation. Figure 3 provides an example of how Public  Assistance funded hazard mitigation measures for a critical facility that  was damaged by Sandy-related flooding.
section_title: Community Development Block Grant-Disaster Recovery Program Funds Helped Sandy-Affected States Explore New Disaster Resilience Approaches, Pay Project Costs, and Implement Additional Hazard Mitigation Initiatives
paragraphs: Congress appropriated $16.0 billion in the Sandy Supplemental to HUD’s  Community Development Fund for disaster relief, long-term recovery,  restoration of infrastructure and housing, and economic revitalization.  This program is designed to address needs not met by other disaster  recovery programs—including but not limited to disaster resilience  initiatives—particularly for low and moderate income persons. The Sandy  Supplemental directed these funds to be available for areas most  impacted and distressed as a result of Presidentially-declared major  disasters from 2011-2013.
HUD allocated $930 million of the Sandy Supplemental appropriation to  fund resilient recovery projects that resulted from Rebuild by Design—a  competition sponsored under the authority of the America COMPETES  Reauthorization Act of 2010—to promote innovative disaster resilience  solutions in the Sandy-affected area that are compatible with local  circumstances and then to fund selected solutions. awarded funds ranging from $10 million to $335 million to four  jurisdictions in the Sandy-affected area that also received other CDBG- DR funding. Building on lessons learned from Rebuild by Design, HUD  later announced that it would use $1 billion in CDBG-DR to fund a  nationwide competition—the National Disaster Resilience Competition— with the aim of helping communities inside and outside the Sandy- affected area explore how they can recover from a past disaster and  avoid future disaster losses. Applicants were required to link their  proposals to the disaster from which they are recovering while  demonstrating how they will reduce future risks and advance broader  community development goals.
Pub L No. 111-358, § 105, 124 Stat. 3989 (2011) (codified at 15 U.S.C. § 3719). funds to be at least 1 foot above the base flood elevation level. According  to HUD officials, such efforts are classified according to the type of  activity performed and the disaster resilience measures within each  activity are not isolated and are therefore unable to be tracked separately.  As a result, HUD cannot break down exactly how much of the remaining  Sandy Supplemental appropriation that has been or will be used to help  enhance disaster resilience, although some of the appropriation is being  used for those purposes.
New York City and the states of New York, New Jersey, Connecticut,  Rhode Island, and Maryland, among others, received a CDBG-DR  allocation that was not part of one of the resilience competitions. State  officials we interviewed that reported receiving CDBG-DR said it served  as a complement to FEMA-funded mitigation activities in two ways. First,  CDBG-DR was used, in some cases, to cover all or part of the applicant’s  share of HMGP and Public Assistance project costs if the project was  determined to be CDBG eligible. Second, CDBG-DR funded some of the  same type of mitigation activities that HMGP typically funds, such as  acquisition and elevation of properties in high-risk areas, thereby  increasing the number or scope of these projects states were able to  offer. Figure 4 provides an example of an acquisition and demolition  project undertaken by one Sandy-affected locality using 100 percent  CDBG-DR funds to cover project costs.
section_title: FTA’s Emergency Relief Program Helped State and Local Transit Authorities Take Actions to Prevent Future Damages
paragraphs: FTA received $10.9 billion under the Sandy Supplemental appropriation  for the new Public Transportation ERP, which funds transit authority  recovery, relief, and resilience projects and activities in areas affected by  Hurricane Sandy. ERP is intended to provide operating assistance and  capital funding to aid recipients and sub-recipients in restoring public  transportation service, and in repairing and reconstructing public  transportation assets as expeditiously as possible following an  emergency or major disaster that affects a wide area. Eligible projects  include emergency operations; emergency repairs; permanent repairs;  actual engineering and construction costs on eligible projects; and  resilience projects designed to protect equipment, facilities, and  infrastructure from future damage.
An initial FTA damage assessment in February 2013 estimated the costs  of repairing facilities damaged by Hurricane Sandy in New York and New  Jersey to be about $5.8 billion. As of May 2015, FTA has allocated $9.3  billion for recovery and resilience projects to public transportation  agencies affected by Hurricane Sandy. According to FTA officials, the  agency has obligated about $4.2 billion and disbursed about $938 million  to reimburse transit agencies for emergency response, recovery, repair,  and resilience costs. Generally, the federal cost share for FTA ERP  projects is not to be more than 80 percent of the total project cost, and the  federal cost share for competitive resilience projects is 75 percent of the  total project cost. recovery expenses and approximately $4.9 billion for resilience projects,  most of which were selected through a competitive grant process. Figure  5 provides an example of how ERP’s competitive resilience awards are  expected to protect New York City transit from future damages.
Funds are awarded to eligible agencies based on the demonstrated costs of responding  to and recovering from an emergency or major disaster. Funds are also awarded to  affected agencies for projects that improve the resiliency of public transportation assets  and infrastructure to future emergencies or disasters.
section_title: USACE Has Conducted Studies and Undertaken Projects to Help Sandy- Affected Areas Understand and Address Future Flood Risk
paragraphs: Language in the Sandy Supplemental charged USACE with reducing  future flood risk in ways that will support the long-term sustainability of the  coastal ecosystem and communities, and reduce the economic costs  associated with large-scale flooding. It also mandated the North Atlantic  Coast Comprehensive Study, which has the following goals: (1) reduce  flood risk to vulnerable coastal populations, and (2) promote coastal  resilient communities to ensure a sustainable and robust coastal  landscape system. USACE released the North Atlantic Coast  Comprehensive Study—covering more than 31,000 miles of coast line— in January 2015. More than 8 million people live in areas at risk of coastal  flooding. Along the U.S. Atlantic coast alone, almost 60 percent of the  land that is within a meter of sea level is planned for further development.  According to USACE officials, the comprehensive nature of the study  represents a significant improvement in planning to manage coastal flood  risk. In addition to the study, USACE has dedicated funding and  undertaken a number of coastal risk reduction projects and studies in five  Sandy-affected states—Delaware, New Jersey, New York, Rhode Island,  and Virginia. Figure 6 provides an example of one such study and  associated projects designed to increase disaster resilience of  communities at risk for flooding along one coastal system.
section_title: State Officials Reported Successes Using Federal Funds to Enhance Disaster Resilience, but Experienced Challenges That Limited Their Ability to Maximize Those Funds
paragraphs: The 16 groups of state and city officials from the Sandy-affected area that  we interviewed reported successes in leveraging federal Sandy recovery  efforts to enhance disaster resilience. However, in the interviews and in  13 follow-up survey responses, officials also reported a series of  challenges that hindered their ability to maximize federal funds in the  wake of recent disasters. Challenges generally fell into three categories:  (1) specific challenges with the implementation of postdisaster programs  where program implementation was not always consistent with agency  disaster resilience priorities, (2) challenges from the broader structure of  disaster resilience funding that limited a comprehensive approach to  reducing overall risk, and (3) local challenges that are not directly in the  federal purview but may be exacerbated by other challenges that are.
subsections: section_title: State Officials Reported Successes with Their Efforts to Enhance Disaster Resilience
paragraphs: Thirteen of the 16 groups of state and city officials we interviewed said  that they were able to effectively or very effectively use the post-Sandy  effort as an opportunity to make communities more resilient against future  disasters. Officials cited residential acquisitions or elevations, the  purchase of generators to ensure the continuity of operations of critical  facilities, increased local hazard mitigation planning, and other projects  such as those discussed previously as key efforts supported by federal  funding in the Sandy recovery.
In addition, officials from 12 of 16 states and cities said that their leaders  value efforts to enhance community resilience to a great extent, as  demonstrated by actions like the availability of state funding for mitigation,  legislative efforts to strengthen building codes, or the establishment of  state offices to focus on disaster resilience efforts. For example, New  York City strengthened building codes to account for long-term sea level  rise, and the Governor of Maryland issued an executive order that new  construction and improvements of state structures must consider potential  impacts of climate change. In addition, states that received a presidential  major disaster declaration as a result of Hurricane Sandy collectively  used more than 20 percent of the FEMA Public Assistance funds they  received for disaster recovery and repair to implement hazard mitigation  measures.
section_title: State Officials Reported That Challenges Implementing Hazard Mitigation Grant Program and Public Assistance Limited Their Ability to Maximize Those Programs’ Opportunities
paragraphs: One of the goals of the NDRF is to integrate hazard mitigation and risk  reduction opportunities into all major decisions and reinvestments during  the recovery process. Similarly, the National Mitigation Framework calls  for governments at all levels to capitalize on opportunities during the  recovery building process to further reduce vulnerability. However, state  and city officials we interviewed and surveyed reported experiencing or  perceiving several conditions that limited achievement of that goal with  FEMA’s PA and HMGP programs, including (1) the complexities of the  hazard mitigation planning process, (2) FEMA PA and HMGP staff  turnover, (3) limitations on eligibility, and (4) lack of FEMA officials’  support for PA-funded hazard mitigation during project formulation. FEMA  has a stated goal of integrating hazard mitigation into the recovery  process to capitalize on opportunities to reduce future risk, but state  officials’ experiences with recovery efforts from Hurricane Sandy and  other disasters in the 2011-2013 timeframe suggest that, in some cases,  implementation of these programs has not always been consistent with  that goal.
subsections: section_title: Hazard Mitigation Planning Process
paragraphs: As shown in figure 7, 8 of 13 states and cities responding to our follow up  survey reported that the complexity of FEMA’s review process for hazard  mitigation plans limited their ability to maximize disaster resilience as part  of the recovery. In interviews, officials said FEMA’s focus on detailed,  nationally-standardized requirements during the review process for  hazard mitigation plans often overshadowed the substance of the plans  or, according to state officials, the plans’ capacity to meet local needs.  FEMA requires that in order to be eligible for HMGP funding, both the  state and local jurisdiction have a hazard mitigation plan that has been  reviewed and approved by the agency. In order to be approved, a plan  must document the planning process—including how it was prepared,  who was involved, and how public comments were integrated—and must  also include a comprehensive range of mitigation actions to address each  hazard identified by the plan’s risk assessment, among other  requirements. However, in 1 state, officials said that two of their localities  had decided not to pursue FEMA-approved hazard mitigation plans— forgoing eligibility for HMGP as a result—because of the agency’s  requirements and review comments for the plans. For example, the  officials stated that among the reasons why FEMA returned the two plans  were that they did not contain a definition of “hurricane,” did not follow the  agency’s formatting guidelines, or because they included hazard  mitigation activities that were not eligible for FEMA funding but may have  been of benefit to the local jurisdictions. A senior FEMA official told us  that they require the plans to be detailed so that they result in  preidentified hazard mitigation projects that can be implemented quickly  after a disaster.
Ten of the 13 states and cities responding to our follow up survey  reported that turnover among either PA or HMGP staff at joint field offices  or recovery offices was a challenge that limited their ability to maximize  disaster resilience as part of the recovery, as illustrated by figure 8.state official said that the high rate of turnover at FEMA causes  discontinuity in grant staff expertise, which hinders the state’s ability to  efficiently submit applications. Another said that the rate of turnover  among project specialists for FEMA’s Public Assistance program was a  frequent complaint of applicants and led to inconsistent guidance and  repetition of project formulation processes. For example, 1 state reported  that what had been acceptable to one FEMA reviewer may not be to the  standards of the reviewer’s successor, requiring the state to go back to  square one and re-visit everything that was previously agreed upon. The  state reported that changes in FEMA personnel resulted in the need to  “retread ground long-since covered” and resulted in inconsistent guidance   One  from FEMA personnel. FEMA officials acknowledged that staff turnover in  joint field offices and recovery offices has been a long standing challenge.
State and city officials in the Sandy-affected region that we interviewed  and surveyed reported that they were not always able to capitalize on  federal recovery assistance to strengthen resilience because the kind of  projects they thought would be most useful were not eligible. Figure 9  shows that 7 of 13 states and cities responding to our follow-up survey  reported that the type of projects eligible for HMGP limited their ability to  maximize resilience during the recovery effort, and 8 of 13 said the same  for PA. Concerns about eligibility generally centered on unique  attributes of a locality or region that did not align with HMGP regulations  and guidance designed for broad national characteristics. For example,  one hazard mitigation official suggested that more needed to be done to  address the needs of dense urban areas, including hazard mitigation  projects suited to those environments. In particular, elevation is not  feasible for historic row homes in these urban areas, and the property  values in some areas may make it difficult to demonstrate cost- effectiveness of the acquisition of homes in flood prone areas.
Although law, regulation, and grant guidance prescribe the types of  projects eligible for these programs, there is sometimes flexibility in  interpreting those criteria to be responsive to state and local needs. State  Hazard Mitigation Officers we interviewed reported that they frequently  communicate with their counterparts in other states to share information  and ideas, and discovered inconsistent application of flexibility in making  eligibility determinations across states and regions. As shown in figure 10,  7 of 13 states and cities responding to our survey said that FEMA officials  in their region had not applied discretion, under the current regulations  and guidance, in a way that maximizes hazard mitigation opportunities  under the HMGP program. For example, in interviews officials from 1  state told us that their regional FEMA officials determined HMGP could be  used only to elevate utilities, such as water heaters, to the first floor,  because elevation was to be to base flood elevation plus 1 foot, and any  other floor would be higher than that, and therefore not considered a  “reasonable cost.” According to state officials, for practical and aesthetic  reasons, homeowners declined to participate unless they could elevate  utilities to the attic level. When we described this scenario to a senior  official from the FEMA Mitigation Directorate, the official said that  elevation of utilities to an attic generally could be determined eligible, and  the small additional cost in that situation should not be a barrier to  mitigating their risk from future disasters. The official later followed up and  found that FEMA employees in that region had misunderstood FEMA’s  authority to allow the additional cost for utilities.
Another factor states reported affecting HMGP and PA eligibility is the  benefit-cost calculation. For both HMGP and PA, FEMA typically requires  a benefit cost analysis to compare the cost of a hazard mitigation project  with its future benefits. Eight of 13 states and cities responding to our  follow up survey reported that they experienced challenges with the  consideration of appropriate benefits (e.g., environmental) in at least one  of these programs, as shown in figure 11. For example, acquisition  projects, which result in open space, can enhance environmental quality  in a community. According to a senior official in FEMA’s Mitigation  Directorate, the goal of HMGP is to protect against damages from future  severe weather, and it would not be appropriate to consider benefits that  do not relate directly to that purpose. However, FEMA has already taken  some action that may help to address this problem. FEMA issued a policy  in 2013 describing additional environmental benefits that could be  considered for property acquisitions. In addition, on the basis of an  analysis by the agency’s Risk Reduction Division, FEMA issued guidance  in 2013 that the acquisition or elevation of structures located within the  100-year floodplain will be considered cost-effective as long as the total  project costs are under $276,000 for acquisitions and $175,000 for  elevations. For projects meeting these guidelines, applicants are not  required to submit a benefit cost analysis. During our interviews, officials  from multiple states praised this practice, in part because it reduced the  burden for them and their local partners and in part because it recognized  the overall benefit of elevation, even when some elevation projects may  not have been determined to be cost-effective under the previous  guidelines because of variations in construction costs across regions.  Multiple state officials told us during interviews that they appreciated  FEMA’s decision to establish a standard benefit cost analysis threshold  for these hazard mitigation activities. On the other hand, some state  officials cautioned that by making more projects eligible without a benefit  cost analysis requirement, predetermined benefits can lead to more strain  on limited resources and make the prioritization process more difficult for  state decision-makers.
Identifying PA Hazard Mitigation Projects  Generally, when applicants wish to be  considered for Public Assistance funding, they  work directly with FEMA Project Specialists.  Project Specialists are primarily responsible  for collecting information about potential  projects and for assessing and determining  project eligibility. The formal documentation of  this process is called a project worksheet.  Project worksheet guidance states that project  specialists should complete a hazard  mitigation proposal if the applicant requests  hazard mitigation measures, and in such  cases, a justification for the proposed  mitigation measures must be provided.
Specialists had avoided writing or had inadequately prepared hazard  mitigation proposals prior to Hurricane Sandy. In addition, a seventh  respondent reported that the state did not experience Project Specialists  actively discouraging hazard mitigation, but not encouraging it when  working with locals to identify projects had been a challenge.
FEMA’s Project Worksheet Development Guide, the internal guidance for  completing project worksheets, directs project specialists to ask  applicants if they would like to pursue hazard mitigation activities but does  not direct the employees to actively identify opportunities for hazard  mitigation during the process of scoping a project. On the contrary, the  guidance categorizes hazard mitigation within a class of “special  considerations,” which can result in additional processes or layers of  review. Although the guidance notes that hazard mitigation is a priority for  FEMA and suggests that project specialists should sometimes consider  providing an explanation when it is not implemented, the agency’s  position to make hazard mitigation a priority is not fully emphasized  throughout the guidance.
Federal Emergency Management Agency’s  (FEMA) Hazard Mitigation Assistance  FEMA has multiple programs to help states  and localities enhance disaster resilience. The  primary programs for mitigation against all  hazards are Hazard Mitigation Grant Program  (HMGP) and the Pre-Disaster Mitigation  Program (PDM). In addition, the Flood  Mitigation Assistance Program is available  through the National Flood Insurance Fund for  flood hazard mitigation projects.   Generally, PDM receives annual  appropriations that are small, compared with  the amount of funding typically provided  following a disaster. In fiscal year 2014, for  example, the total appropriation for the entire  nation was $25 million. Each of the 50 states,  the District of Columbia, and U.S. territories  automatically receives at least either 1  percent of PDM allocations or $575,000,  whichever is less. Each of these entities is  eligible for additional PDM awards on a  competitive project basis, regardless of  disaster history.   HMGP, by contrast, is funded through FEMA’s  Disaster Relief Fund, and is available only in  the wake of a presidentially-declared  disaster—generally 15 percent of the first $2  billion in disaster assistance awarded in  association with a declared disaster. As a  result, nationwide annual HMGP spending  tends to be significantly higher than annual  PDM allocations, but the size of any individual  award will vary. In addition, in any given year,  some states and other nonfederal  governments may not be eligible for HMGP. is not documented in FEMA’s current internal guidance for completing  project worksheets. In addition, FEMA officials told us that making  adjustments to project specialists’ roles in identifying hazard mitigation  opportunities during the project worksheet formulation process could help  to further integrate disaster resilience into the recovery process.
Given the challenges state and local officials experienced during the  Hurricane Sandy recovery, evaluating the extent that corrective actions  are needed to help ensure FEMA consistently reinforces its resilience  goals in the NDRF and NMF could better position FEMA to assist state  and locals in maximizing opportunities to enhance disaster resilience.  According to FEMA officials, the agency has launched a reengineering  initiative to develop a new operating model for PA that is intended to  enable greater efficiency and improve the delivery of disaster assistance.  FEMA plans to test the new model during 2015 and then begin full  implementation during 2016 or 2017, depending on how many disasters  occur during that time. In addition, according to officials, FEMA is  exploring the effect of and potential solutions to staff turnover as part of  this effort. Whether as part of the PA review or outside of it, identifying  corrective actions that respond to the experiences of state officials with  responsibility for resilience during recovery from the most recent multi- billion dollar disaster could enhance FEMA’s ability to meet the goal of  integrating hazard mitigation into the recovery process. For example,  FEMA could enhance communication, guidance, training, or  documentation of decision making to address issues arising from staff  turnover, promote maximum flexibility within the law to meet local needs,  and ensure that PA project specialists appropriately identify hazard  mitigation opportunities. FEMA officials acknowledged the importance of  reviewing the challenges identified by state and local officials and told us  that they appreciated us bringing these challenges—which they have not  necessarily already planned to address in their review—to their attention.
section_title: State and Local Officials Experienced Challenges Enhancing Resilience in the Postdisaster Recovery Environment
paragraphs: The bulk of federal disaster resilience funding, such as PA and HMGP,  that is provided to states and localities comes after they have  experienced a disaster, particularly a large or catastrophic disaster.  Although there are advantages to focusing on disaster resilience in the  postdisaster environment, our interviews and follow-up surveys revealed  that the emphasis on spending in the postdisaster environment and the  inherent fragmentation of federal funds and programs in the post- catastrophe environment limited states’ ability to plan and prioritize for  maximum risk reduction.
subsections: section_title: Federal Emphasis on Postdisaster and Catastrophic Disaster Resilience Funding
paragraphs: Except when supplemental funding is approved following a catastrophic  disaster, PDM and HMGP are the primary federal programs that provide  funding to states and localities to help enhance their disaster resilience— PDM for pre-disaster mitigation and HMGP in the postdisaster  environment. As demonstrated in figure 13, PDM spending has  historically been a fraction of HMGP spending. In addition, PDM grants  limit states to a certain number of applications per year—for instance, in  fiscal year 2014, states could submit a maximum of 11 applications, of  which only 2 could be for projects, as opposed to hazard mitigation  planning or management costs, which according to officials, limits the  states’ capacities to implement “brick and mortar” hazard mitigation  projects with the pre-disaster grant funds.
As demonstrated by the Sandy Supplemental and the associated  recovery effort, in the wake of a catastrophic disaster, affected areas can  receive substantial sums to enhance disaster resilience. For example,  HMGP provided approximately $1.7 billion to New York and New Jersey  following Hurricane Sandy. In addition, other programs like CDBG-DR  and FTA’s ERP provided billions of disaster resilience dollars that are not  available on an annual basis. There are advantages to making funds  available in the postdisaster environment. For example, the recent and  tangible experience with the disaster can help motivate individuals and  communities to focus on mitigating their risk, because they do not want to  relive the losses they have just experienced or to incur losses they  observe in their neighbors’ experience.
State officials we interviewed confirmed that, in their experience, local  applicants were more likely to invest their own resources in hazard  mitigation activities following a disaster. In some states, state officials  reported Hurricane Sandy was a catalyst to strengthen the state’s culture  of resilience. Officials in the most severely affected states—for example,  New York and New Jersey—told us that disaster resilience is now a point  of discussion across sectors and throughout communities that had not  previously pursued hazard mitigation. Of the six officials who said their  state’s culture of resilience had not changed as a result of Sandy, three  attributed the lack of change to the less severe impact experienced by  their states, relative to the impact on other states that had been affected,  and one official reported that seeing the damage sustained in New York  and New Jersey made citizens and leaders more aware of their own risk.  Another official stated that the culture of resilience in his state had already  changed prior to Sandy, following two disasters that significantly affected  business and employment interests.
section_title: Challenges in the Postdisaster Environment
paragraphs: Although 9 of 16 groups of state officials we interviewed said that disaster  resilience and hazard mitigation activities should be integrated into  recovery efforts within the first hours and days after a disaster occurs, 3  said that actually happened in the Hurricane Sandy recovery. Although all  of the officials said that disaster resilience and hazard mitigation activities  should be incorporated within the initial hours to initial weeks, 5 of the  groups we interviewed said that it was months to years before that  happened in the wake of Hurricane Sandy because, in part, they were  focused on more immediate recovery concerns such as restoring power.
In some states, officials with primary responsibility for hazard mitigation  noted that they wore other hats in the emergency operations center in the  initial hours to days and were too focused on response functions to think  about hazard mitigation. Of the 7 that said hazard mitigation should be  integrated in days to weeks (rather than hours to days) some also  expressed skepticism about the feasibility of focusing on future disaster  resilience activities while life-saving activities were in progress. For  example, one State Hazard Mitigation Officer told us that it is more  important to restore power to the affected area quickly than it is to ensure  that the power grid is repaired in a manner that mitigates future disaster  risk.
During our discussions about how soon after a disaster hazard mitigation  and disaster resilience planning should be integrated into recovery,  officials noted that a more effective approach to disaster resilience would  be to plan and implement hazard mitigation before a disaster occurs. In  this regard, 12 of 13 states and cities responding to our survey reported  that the emphasis of federal resources on the postdisaster environment  challenged their ability to maximize federal disaster resilience  investments, as illustrated in figure 14.
A related challenge that state and city officials we interviewed discussed  stems from the general structure of HMGP funding. Although, outside the  recent response to Hurricane Sandy, HMGP is generally the primary  vehicle through which the federal government has invested in disaster  resilience, state and local officials noted that the (1) amounts, (2) political  context, and (3) timing and uncertainty associated with the program can  lead to a less coherent approach to reducing overall risk.
In terms of amounts, a senior FEMA official said that when HMGP is  awarded for most disasters, the total award is generally not enough to  address larger critical infrastructure needs, and as a result, states and  localities tend to focus on smaller projects to the exclusion of those that  have more potential to reduce their most critical risks. One state official  said that localities tend to avoid including those larger needs in hazard  mitigation planning, because they did not even think it was feasible to  consider addressing them.
State officials also described a delicate political environment in the wake  of disasters where decisions about what hazard mitigation projects to  fund can be challenging. A senior MitFLG official stated that political  pressure can often dictate how and where states and localities spend  resilience funding in the wake of a disaster. For example, elected officials  can direct the use of disaster resilience funding to one or a few large- scale infrastructure projects or spread the funds throughout the state for  numerous small projects across multiple communities. The official said it  has been his experience that the state officials often choose to distribute  the funds throughout multiple communities in a way that makes a positive  impact on individuals and sometimes communities, but not in a way that  necessarily changes the overall risk profile of the state.
Officials in one state we visited described an example where they had  initially planned to use HMGP funds for flood control measures in the  economic center of a small town that regularly floods—a project they had  determined was the best path to enhancing the state’s overall disaster  resilience. However, in the wake of the disaster, political considerations  trumped their experience and professional judgment, and the funds were  used instead to elevate beachfront properties.
Estimating Hazard Mitigation Grant  Program Awards  The Federal Emergency Management  Agency’s (FEMA) Office of the Chief Financial  Officer (OCFO) calculates Hazard Mitigation  Grant Program (HMGP) allocations using  estimates from FEMA program managers,  which reflect expended and projected costs.  Pursuant to FEMA’s Hazard Mitigation  Assistance Guidance, the OCFO is to provide  preliminary estimates to states at the 35-day  and 6-month marks post-declaration. At 12  months post-declaration, the OCFO is to  provide recipients with a “lock-in” figure, which  is the maximum that FEMA can obligate to the  state for eligible HMGP activities.
Finally, in terms of timing and uncertainty, officials reported being  challenged by the manner in which FEMA estimates and finalizes HMGP  awards. Because HMGP, by statute, is awarded as a portion of all other  FEMA disaster assistance awarded in association with a given disaster,  there is lag and uncertainty in the process of estimating and finalizing  awards. States and localities typically receive the final estimate for HMGP  awards 12 months after a major disaster declaration, which coincides with  the deadline for states to submit their HMGP project applications.  Moreover, in the wake of catastrophic disasters like Hurricane Sandy,  FEMA’s Office of the Chief Financial Officer is not always able to provide  “lock-in” figures at the 12-month mark. FEMA officials stated that in  catastrophic disasters, such as Hurricane Sandy, a prolonged focus on  projects such as debris removal, emergency protective measures, and  providing survivor assistance can delay their capacity to provide  estimates of the amount of HMGP funding that is available. In addition,  when states are approved for additional PA funding after the 12-month  mark, states can request adjustments to the amount of HMGP funding  available.
Although states can get approved extensions—something that has  happened in 75 percent of recent disasters, according to FEMA officials— state officials still reported challenges with the timing of final estimates. In  interviews, state officials said they experienced delays in receiving their  final estimates after Hurricane Sandy, and one state reported that it did  not receive the final estimate until the summer of 2014. Shown in figure  15, 11 of 13 officials responding to our follow-up survey reported that they  experienced challenges in the ability to plan, develop, or prioritize HMGP  project applications prior to knowing how much funding they are going to  receive for HMGP projects. A senior FEMA official told us that they  encourage states to submit HMGP applications early, prior to receiving  their lock-in estimates, because localities should have already identified  their priority projects through the hazard mitigation planning process.
However, state officials told us that they seek to optimize the projects  based on the funds available, which could mean the difference between  allocating all the funds to one larger project or deferring that project and  allocating to multiple smaller projects depending on the total amount, and  this optimization cannot occur when the amounts are unknown before  applications are due. In addition, 1 official reported that projects identified  in local hazard mitigation plans are generally not developed to the level  required for an HMGP application, because few communities have the  resources to dedicate to this effort without knowing whether the project  will ultimately be funded.
When disaster resilience funds, such as in the Sandy Supplemental, are  appropriated in response to catastrophic events, multiple federal  departments and programs share responsibility for enhancing disaster  resilience during recovery efforts, and the risk of fragmentation across the  multiple funding streams increases. As a result of the postdisaster  response, different programs are initiated at different points in the wake of  the disaster, making it more difficult for state and local officials to plan to  use federal funds in a way that comprehensively addresses overall risk  reduction. For example, states become eligible for PA once the President  grants the state a major disaster declaration, but HUD CDBG-DR funds  become available only if Congress makes a special appropriation as a  result of a catastrophic disaster, such as Hurricane Sandy. More  specifically, following Hurricane Sandy, FEMA Public Assistance funding  became available to most states within days to weeks, while HUD CDBG- DR funding was not available for several months, because the Sandy  Supplemental was enacted 3 months after the storm occurred. In  addition, other funds that can be used for disaster resilience—related  construction, such as FTA’s Emergency Relief Program, were  appropriated in the Sandy Supplemental and could be obligated only after  FTA was able to publish regulations governing the use of the funds  because it was standing up a newly created program. In response to our  follow up survey, 12 of 13 states and cities reported that navigating the  multiple funding streams and various regulations is a challenge that  affected their ability to maximize disaster resilience opportunities, shown  in figure 16.
State officials we interviewed said there is no focal point in their state with  the time, responsibility, and authority to ensure a holistic approach to  reducing risk and increasing disaster resilience. Although state hazard  mitigation plans are to identify funding sources to pursue disaster  resilience, we found variation in the extent to which these plans actively  identified multiple funding streams. In addition, especially in the wake of a  large disaster like Sandy, State Hazard Mitigation Officers do not always  have visibility over all federal funding streams available for hazard  mitigation. For example, all of the 13 State Hazard Mitigation Officers we  interviewed said that they had little or no involvement with coordinating  hazard mitigation activities with FTA’s ERP and most had minimal  visibility over CDBG-DR disaster resilience-related projects, apart from  the program’s ability to be used to cover the required applicant’s share of  HMGP and PA projects. Figure 17 illustrates the multiple timeframes and  program regulations that confronted state officials in the wake of  Hurricane Sandy.
With the multiple rules, regulations, and timelines, state officials  responsible for enhancing disaster resilience who we interviewed  reported that it is difficult to navigate and leverage the multiple programs  available during recovery efforts. As illustrated by figure 18, 11 of the 13  states and cities that responded to our survey reported that the  timeliness, availability, or usefulness of the federal government’s  guidance about what type of federal assistance is available after a  disaster, and how it can be used to most effectively pursue disaster  resilience, was a challenge that reduced their state’s ability to maximize  resilience opportunities. For example, one state official who responded to  our survey said that key stakeholders, including state and local officials  and representatives from other federal disaster recovery programs, were  not adequately represented in discussions that occur at FEMA joint field  offices and disaster recovery centers, which are often the state’s focal  point for guidance during the recovery effort. Other officials stated that the  available guidance could be variously incomplete, overwhelming,  contradictory, or require numerous clarifications. For example, officials in  1 state interpreted guidance to mean that moving critical infrastructure out  of the floodplain was an activity eligible for PA funding, but they were later  told by FEMA officials that the guidance did not apply to their specific  circumstance. Officials in another state said that agency guidance  sometimes seemed inconsistent with applicable portions of the Code of  Federal Regulations.
The multiple federal regulations, if they are not harmonized, can also  create inefficiency or the appearance of inefficiency for the states and  localities. For example, officials from 10 of the 13 states and cities cited  challenges due to inefficiencies in the implementation of environmental  planning and historic preservation (EHP) reviews that prolonged work on  projects, shown in figure 19. EHP reviews are required for many  disaster recovery projects that receive federal funding, because of  requirements that the agencies comply with certain federal environmental  protection laws including the National Environmental Policy Act. State  officials told us that these reviews were often time-and resource- consuming, which could dissuade individuals from pursuing hazard  mitigation projects. For example, one state official state said that  managers of a marina damaged by Sandy chose not to pursue PA  funding because of concerns that the required EHP review would delay  the project’s completion and potentially prevent the marina from  reopening in time for the following season. In addition, officials said that  FEMA’s EHP reviews were sometimes redundant, with similar reviews  required by other federal or state agencies. For example, both FEMA and  HUD require an EHP review, which in some cases could result in a  duplication of requirements.
SRIA amended the Stafford Act and required the President to establish  an expedited and unified interagency review process to ensure  compliance with environmental and historic preservation requirements  under federal law relating to disaster recovery projects in order to  expedite the recovery process. As a result, a steering group led, in part,  by FEMA and consisting of federal partners in emergency management,  environmental quality, and historic preservation was established to  develop and implement a more efficient process for federal EHP reviews  for disaster recovery projects. In addition, according to HUD officials,  while the Unified Federal Review process is underway, a Sandy-specific  team—the Federal Sandy Infrastructure Permitting and Review Team— has been established to facilitate coordinated review and permitting of the  certain infrastructure projects, as recommended in the Hurricane Sandy  Rebuilding Strategy.
In response, through the Unified Federal Review process, 11 federal  agencies that perform environmental and historic preservation reviews  during disaster recovery entered into a memorandum of understanding to  coordinate their independent review processes in an attempt to expedite  decision making and implementation of recovery projects. The Unified  Federal Review Process was established and effective on July 29, 2014  through the Memorandum of Understanding Establishing the United  Federal Environmental and Historic Preservation Review Process.  It is  too soon to evaluate the extent to which the Unified Federal Review, as  implemented, has resulted in harmonized and streamlined review  requirements for applicants.
In keeping with the Unified Federal Review agreement, FEMA’s 2015  Hazard Mitigation Assistance Guidance specifies that the agency can  accept EHP documentation from other federal agencies if the  documentation addresses the scope of the FEMA-approved activity and  FEMA verifies that it meets FEMA’s EHP compliance requirements. In  addition, according to a FEMA official there are multiple complicating  factors that could affect applicants undergoing EHP review; however, the  official stated that the vast majority of FEMA projects—when the  environmental planning and historic preservation review process is begun  early during project planning—are not delayed. Moreover, a senior FEMA  official responsible for EHP compliance noted that during EHP reviews  the act of considering various alternatives can actually result in solutions  that promote greater disaster resilience.
section_title: State Disaster Resilience- Building Efforts Are Dependent on Local Capacity and Participation, Which Can Present Challenges
paragraphs: Although states are usually the grant recipients for PA, HMGP, and  CDBG, local partners or federally-recognized Indian tribes often plan and  execute the projects these grants fund. Although state officials we  interviewed reported widespread support for disaster resilience  investment, they also reported some challenges with capacity and  willingness at the local level.
Illustrated in figure 20, 10 of 13 states and cities responding to our follow  up survey said that the capacity of localities to access or manage federal  funds for hazard mitigation was a challenge. In some cases localities do  not have full-time staff dedicated to disaster resilience-related activities,  and may have difficulty keeping hazard mitigation plans current, making  grant applications, or monitoring and reporting on compliance with  multiple grant requirements. For example, 11 of 13 respondents to our  follow-up survey reported that local applicants may have difficulty  collecting the information required to complete FEMA’s Benefit Cost Analysis Tool for their PA or HMGP applications, as shown in figure 21.Officials in 1 state said that the amount of documentation required for the  benefit cost analysis limited the number of project applications the state  was able to submit.
In addition, some officials reported that localities or individual businesses  or homeowners were not willing to pursue hazard mitigation opportunities  because of competing concerns. For example, some communities may be  hesitant to pursue acquisition activities, which result in permanently  replacing homes or businesses with open space, because of the potential  to diminish the tax base or limit future economic development  opportunities. In our follow-up survey, 8 of 13 respondents said that the  willingness of individuals to pursue hazard mitigation opportunities  presented a challenge to their ability to maximize disaster resilience, as  demonstrated in figure 22.communities with high flood risk may be unwilling to relocate.
section_title: A Comprehensive Federal Investment Strategy Could Enhance Disaster Resilience and Reduce Fiscal Exposure
paragraphs: The President and Congress have taken multiple steps to enhance the  federal government’s focus on disaster resilience, including issuing new  EOs and presidential policy directives (PPD), and enacting SRIA. As we  have previously concluded, complex interagency and intergovernmental  efforts—such as the federal government’s focus on enhancing the  nation’s disaster resilience—can benefit from a national strategy. The  issuance of EOs and PPDs in the aftermath of Hurricane Sandy  demonstrates the federal government’s focus on disaster resilience,  linking hazard mitigation and recovery to break the cycle of damage- repair-damage. For example, the President signed EO 13632 on  December 7, 2012 creating the Hurricane Sandy Rebuilding Task Force  and charged the task force with developing the Hurricane Sandy  Rebuilding Strategy. It also charged the task force with taking into  account existing and future risks and promoting the long-term  sustainability of communities and ecosystems in the Sandy-affected  region. In addition, the EO on Sandy rebuilding called for the federal  government to:  1.  remove obstacles to resilient rebuilding in a manner that addresses  existing and future risks and vulnerabilities and promotes long-term  sustainability of communities,   2.  plan for the rebuilding of critical infrastructure damaged by Hurricane  Sandy in a manner that increases community and regional resilience  in responding to future impacts, and  3.  identify resources and authorities that can contribute to strengthening  community and regional resilience as critical infrastructure is rebuilt.
Further, in 2013, the President issued an EO titled Preparing the United  States for the Impacts of Climate Change (EO 13653) and a PPD titled  Critical Infrastructure Security and Resilience (PPD-21), both calling for  the nation to manage risks in a way that makes the United States more  resilient in the future. The President also issued a Climate Action Plan to  improve the nation’s resilience to flooding and better prepare the nation  for the impacts of climate change. The plan directs federal agencies to  take appropriate actions to reduce risk to federal investments, specifically  to “update their flood-risk reduction standards.” In January 2015, to  further the Climate Action Plan, the President released EO 13690,  Establishing a Federal Flood Risk Management Standard. The standard  requires all future federal investments in, and affecting, floodplains to  meet a certain elevation level, as established by the standard. Such  agency actions include those in which federal funds are being used to  build new structures and facilities, or to rebuild those that have been   The new flood risk standard builds on work done by the  damaged.Hurricane Sandy Rebuilding Task Force, which announced in April 2013  that all Sandy-related rebuilding projects funded by the Sandy  Supplemental must meet a consistent flood risk reduction standard.
In addition, Congress passed and the President signed SRIA. The law  authorized several changes to the way FEMA may deliver federal disaster  assistance. For example, it authorizes FEMA to use expedited  procedures in HMGP. As a result, FEMA has issued guidance for  streamlining the program and is planning actions to continue to refine the  changes and measure their effectiveness. SRIA also allows FEMA to  provide up to 25 percent of the estimated costs for eligible hazard  mitigation measures to a state or tribal grantee before eligible costs are  incurred.
In addition, the Hurricane Sandy Rebuilding Strategy—as a result of EO  13632—recognized the need to institutionalize regional approaches to  resilient planning and coordinate Sandy recovery infrastructure resilience  projects. More specifically, one of the recommendations stated that  MitFLG should institutionalize regional approaches to disaster resilience  planning in the NDRF and NMF. In addition, federal agencies have taken  a variety of actions to enhance regional resilience—particularly as they  implemented select Hurricane Sandy Rebuilding Strategy  recommendations aimed at enhancing the Sandy-affected region’s  disaster resilience. The Hurricane Sandy Task Force recommendations  related to disaster resilience and a brief status update for each  recommendation are included in appendix II.
As a result of the recommendations, the Sandy task force developed its  Resilience Guidelines in the spring and summer of 2013. The guidelines  are intended to ensure that federal agencies have a consistent approach  to enhancing disaster resilience and to improve decision making to  ensure wise investments by establishing criteria for those investments.  The Task Force found that the main challenges involved complex  interagency issues that called for a more streamlined approach to  prioritizing the myriad of guidance, executive orders, frameworks, and  plans related to disaster resilience.
We have previously concluded that complex interagency and  intergovernmental efforts can benefit from a national strategy. In 2004, we  identified elements of an effective national strategy including: (1)  identifying the purpose, scope, and particular national problems the  strategy is directed toward; (2) establishing goals, priorities, milestones,  and performance measures; (3) defining costs, benefits, and resource  and investment needs; (4) delineating roles and responsibilities; and (5)  integrating and articulating the relationship with related strategies’ goals,  objectives, and activities.
The NMF, by articulating a vision where the nation shares a culture of  resilience and describing the national capabilities required to focus on  disaster risk and resilience in everyday activities, to some extent serves  as such a strategy in that it has begun to address purpose, scope, and  responsibilities. Although the current framework—the first-ever version— may evolve in future updates to reflect the more expansive and nuanced  understandings that come from sustained attention to an issue and  lessons learned from recent and future events, it already serves the  highest-level functions of an effective national strategy. What the nation  lacks and the framework does not significantly address, however, is  information; direction; and guidance for costs, benefits, and investments  needed to ensure that the nation is prioritizing federal resources in the  most effective and efficient manner possible.
As previously described, states’ and localities’ experiences with the  Hurricane Sandy recovery demonstrate that the fragmentation and the  postdisaster emphasis inherent in the current approach to disaster  resilience investment can create obstacles to most effectively marshaling  resources toward the goal of overall risk reduction. In interviews, senior  officials at FEMA and HUD who provide MitFLG leadership acknowledged  that the current approach does not lead to the most efficient or effective  disaster resilience investments. As one of these officials put it, the federal  government’s current investments aimed at enhancing the nation’s  disaster resilience—for instance, projects such as home acquisitions and  elevations—have benefited individuals and, often, communities, but may  not have effectively reduced states’ overall risk profiles. The official stated  that there are better investments that could be made, bringing into  question whether the federal government is getting the most effective  return on its disaster resilience investments.
Findings of the Sandy Task Force Report also align with some of the  challenges states and city officials reported experiencing. For example,  Sandy Task Force Infrastructure Resilience Guidelines found that there is  significant overlap among various sets of guidelines, and, apart from  regulatory requirements and agency mission, which take primacy, there is  no guidance on prioritizing or differentiating across these sets of   Further, the guidelines also found that relief from regulatory  guidelines.and administrative processes may help communities recover and rebuild  more quickly; however, the guidelines also warned that relief from these  processes may contribute to decisions that are not aligned with resilience  principles, because, for example, immediate needs following a disaster  are prioritized over long-term goals—a condition that relates to challenges  states and cities experience with both the general postdisaster emphasis  and the inherent fragmentation in the postcatastrophe environment.
Although there are benefits to investing in disaster-resilience in a  postdisaster environment, there are challenges and tradeoffs that may  limit effective risk reduction. According to MitFLG officials, the federal  government may not have focused enough attention on pre-disaster  hazard mitigation. A study endorsed by the American Society of Civil  Engineers, the Association of State Flood Plain Managers, the National  Emergency Management Association, and the International Code  Council, among others, found that investing resources and capital to  prevent harm before it occurs is a rational and logical course of action;  however, social, political, and economic realities tend to drive public  choice away from investments that attempt to eliminate or minimize  disasters’ impacts before they occur. More comprehensive  considerations afforded to the balance of pre- and postdisaster  investments could help ensure better returns on investments designed to  limit federal fiscal exposures by buying down risk.
Moreover, information about the benefits of various types of investments  and the context in which they are made—information that could guide  decision makers at every level of government and in the private sector— is largely not available. Conducting a comprehensive study to assess the  cost-benefit trade-offs and return on investment of hazard mitigation  activities would require substantial investment and expertise. FEMA has  developed a modeling methodology to assess the performance of flood  mitigation projects—loss avoidance studies—drawing on experience with  flood programs in actual postproject hazard events. However, modeling  the difference between losses with and without hazard mitigation  measures presents challenges, in part because of the lack of concrete  data to inform assumptions that underpin the models. Another challenge  is that savings depend on two highly uncertain variables—(1) the  frequency and severity of future disasters affecting the property in which  federal investments are made, and (2) the extent to which the federal  government will bear the costs to recover from those disasters. However,  multiple catastrophic events over the last decade—including Hurricanes  Katrina, Rita, Wilma, Ike and Sandy—have resulted in the federal  government bearing anywhere from 75 to 100 percent of the total  recovery costs for FEMA eligible projects across 18 states.
The return on investment of hazard mitigation also depends on the nature  of the specific activities and their impact on the affected property and thus  varies on a project-by-project basis. A 2005 Multihazard Mitigation  Council study attempted to quantify the future savings (in terms of losses  avoided) from hazard mitigation activities related to earthquake, wind, and  flood funded through three major FEMA natural hazard mitigation grant  programs—the Hazard Mitigation Grant Program, Project Impact, and the  Flood Mitigation Assistance Program. The study results indicated that  the natural hazard mitigation activities funded by the three FEMA grant  programs between 1993 and 2003 were cost-effective and reduced future  losses from earthquake, wind, and flood events by $4 for every dollar of  investment. This figure has been cited in congressional hearings and  other arenas to describe the benefits of hazard mitigation; however, it is  dated and generalizes the benefit to all disasters based on a relatively  narrow set of disaster-loss data.
In recent months, leaders and experts from multiple sectors—including a  former FEMA director and representatives from the insurance industry— have called for a more strategic approach to making disaster resilience  investments. Without a comprehensive strategic approach to help  Congress and federal agencies that implement disaster resilience-related  programs prioritize, align, and guide federal investments, the federal  government’s approach has been largely reactionary and fragmented.  Further, the lack of a strategic approach increases the risk that the federal  government and its nonfederal partners will experience lower returns on  investments or lost opportunities to effectively mitigate critical lifelines  against known threats and hazards. It also ignores the question of what  the right balance of federal and nonfederal investment should be and  whether incentives within the various statutes, regulations, and program  policies are appropriately aligned to encourage that balance. Moreover,  because states may rely on postdisaster federal funds to mitigate future  risks, states may not be incentivized to dedicate resources to  comprehensively address their overall risk profiles prior to a disaster  occurring.
An investment strategy to complement the National Mitigation Framework  could help provide a more comprehensive and complete national strategy  to help ensure that the federal government is receiving the most  beneficial return on its disaster resilience funding activities. In particular,  an investment strategy would help to ensure that federal funds expended  to enhance disaster resilience achieve as effectively and efficiently as  possible the goal of reducing the nation’s fiscal exposure as a result of  climate change and the rise in the number of federal major disaster  declarations. For example, an investment strategy could:   identify the most critical components of disaster resilience, such as  critical infrastructure, to help target financial resources in a way that  would protect those components from future disasters;   identify and oversee an approach to developing the information  required to more effectively and accurately determine which, and  under what circumstances, investments in disaster resilience reduce  overall risk, and in turn reduce federal fiscal exposures to disasters; describe the appropriate balance of federal and nonfederal investment  and help to identify how policymakers and program implementers  should structure incentives to help reach this balance; and  consider the current balance between pre- and postdisaster resource  allocation and advise the President and Congress on the benefits and  challenges of the current balance, including whether the nation should  seek to take a more proactive position in funding and encouraging  pre-disaster mitigation activities.
A senior MitFLG official told us that executive-level leadership with  decision-making power is necessary for MitFLG to be able to effect  change. This is particularly important when multiple agencies are  responsible for managing fragmented federal efforts, such as the nation’s  efforts to enhance its overall disaster resilience. An investment strategy  that complements the NMF could help support the ongoing leadership  from the executive and legislative branches by identifying what new or  amended federal policies, regulations, and laws are required to enhance  the nation’s disaster resilience in the most efficient and effective way  possible.
section_title: Conclusions
paragraphs: From fiscal years 2004 to 2013, FEMA obligated over $95 billion in  federal assistance for disaster recovery for presidentially declared major  disasters during that period, and the number of major disaster  declarations has increased significantly in recent decades. In the wake of  Hurricane Sandy, the federal government has demonstrated increased  focus on disaster resilience as a mechanism to limit the nation’s fiscal  exposure to future disasters and has taken steps to improve states’  abilities to use federal disaster recovery funding to incorporate resilient  rebuilding into recovery. However, state and local officials have still  experienced challenges enhancing their states’ overall disaster resilience  when using federal funds through FEMA’s Public Assistance and Hazard  Mitigation Grant Programs.
During the Sandy recovery, states and localities were in some cases  constrained in their ability to pursue hazard mitigation activities using  FEMA PA and HMGP funding streams. State and city officials we  interviewed and surveyed reported experiencing several challenges in the  implementation of FEMA’s PA and HMGP, including the complexities of  the hazard mitigation planning process, FEMA PA and HMGP staff  turnover, limitations on eligibility, and lack of FEMA support for PA  mitigation during project formulation. In addition, officials reported being  challenged by the manner in which HMGP estimates and final awards  were determined, specifically, the timing of the final estimate of HMGP  awards in tandem with the HMGP project application deadline. These  challenges could result in missed opportunities to improve states’ disaster  resilience when providing federal funding for that purpose. Further, such  challenges may inhibit the federal government’s efforts to reduce  vulnerabilities and integrate hazard mitigation into disaster recovery and  its ability to meet risk reduction goals established in the NDRF and  National Mitigation Framework. Assessing the challenges state and local  officials reported, including the extent to which the challenges can be  addressed and corrective actions can be implemented, as needed, may  help ensure that FEMA’s hazard mitigation priorities are effectively  reflected in implementation of the agency’s PA and HMGP programs.
Although federal efforts helped to improve the nation’s disaster resilience  during the recovery from Hurricane Sandy, a comprehensive federal  strategy to prioritize and guide federal investments intended to enhance  the nation’s overall disaster resilience has not been developed. The  federal government primarily funds disaster resilience projects in the  wake of disasters—when damages have already occurred and  opportunities to pursue hazard mitigation may conflict with the desire for  the immediate restoration of critical infrastructure. As the federal  government’s fiscal exposure continues to be threatened by extreme  weather, the increase in the number of major disaster declarations, and— according to some state officials—states’ reliance on the federal  government to fund most of the costs associated with disaster response  and recovery, it is critical that the federal government ensures that it is  getting the best return on its disaster resilience investments. Also,  federal programs that provide disaster resilience funding are fragmented,  resulting in challenges to lowering the overall risk profiles of states and  enhancing the nation’s disaster resilience from future disasters. An  investment strategy to identify, prioritize, and guide future federal  investments in disaster resilience could result in more effective returns on  federal investments and enhance the federal government’s capacity to  effectively mitigate critical lifelines against known threats and hazards.
section_title: Recommendations for Executive Action
paragraphs: To increase states’ abilities to improve disaster resilience and mitigate  future damage when using federal funding in the wake of disasters, we  recommend that the FEMA Administrator take the following action:  Consistent with the goals of the NDRF to integrate hazard mitigation  and risk reduction opportunities into all major decisions and  reinvestments during the recovery process, FEMA should assess the  challenges state and local officials reported, including the extent to  which the challenges can be addressed and implement corrective  actions, as needed.
To help the federal, state, and local governments plan for and invest in  hazard mitigation opportunities to enhance resilience against future  disasters, we recommend that the Director of the Mitigation Framework  Leadership Group, in coordination with other departments and agencies  that are MitFLG members, take the following action:  Supplement the National Mitigation Framework by establishing an  investment strategy to identify, prioritize, and guide federal  investments in disaster resilience and hazard mitigation-related  activities and make recommendations to the President and Congress  on how the nation should prioritize future disaster resilience  investments. Such a strategy could address, among other things, (1)  the extent to which current hazard mitigation and disaster resilience  programs are adequately addressing critical lifelines and critical  infrastructure, (2) an approach to identifying information on what  disaster resilience and hazard mitigation efforts are most effective  against known risks and their potential impacts on the nation’s fiscal  exposure, (3) the balance of federal and nonfederal investments, and  (4) the balance of pre- and postdisaster resilience investments.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to DHS, HUD, DOT, and USACE for  their review and comment. DHS provided written comments on July 21,  2015, which are summarized below and reproduced in full in appendix IV.  DHS concurred with both of our recommendations and described planned  actions to address them. In addition, DHS and HUD provided technical  comments, which we incorporated into the report as appropriate. DOT  and USACE had no comments on the draft report.
DHS concurred with the first recommendation, that the FEMA  Administrator, consistent with the goals of the National Disaster Recovery  Framework (NDRF) to integrate hazard mitigation and risk reduction  opportunities into all major decisions and reinvestments during the  recovery process, assess the challenges state and local officials reported,  including the extent to which the challenges can be addressed and  implement corrective actions, as needed. DHS stated that FEMA is aware  of and acknowledges the challenges state and local officials reported.  FEMA is planning to seek input from federal, tribal, state, and local  stakeholders as part of its efforts to reengineer the PA program, which  they believe will address many of the issues raised in the report. In  addition, in accordance with its strategic plan, FEMA is exploring ways to  improve risk reduction through the Federal Insurance Mitigation  Administration and Recovery mitigation programs, which will focus on  three concurrent work streams: (1) policy, regulation, and statute; (2)  codes and standards; and (3) operations. For example, FEMA will  encourage states, tribes, and localities to adopt and enforce the most  current version of the International Building Code and the International  Resilience Code. DHS anticipates these efforts, among others, to be  complete by December 31, 2016. These actions, if they include an  assessment of the challenges identified by state and local officials, could  address our recommendation and help ensure that FEMA meets its goal  to integrate hazard mitigation into all major decisions and reinvestments  during the recovery process.
DHS also concurred with our second recommendation that the Director of  MitFLG, who is a FEMA official, in coordination with departments and  agencies that are MitFLG members supplement the National Mitigation  Framework by establishing an investment strategy to identify, prioritize,  and guide federal investments in disaster resilience and hazard  mitigation–related activities and make recommendations to the President  and Congress on how the nation should prioritize future disaster  resilience investments. DHS stated that MitFLG recognizes the benefit of  prioritizing federal investments to identify those with the best potential to  enhance resilience against future disasters. DHS also stated that  although MitFLG does not have the authority to compel other federal  agencies to prioritize their funding to achieve a specific goal, it is working  with the interagency group on a variety of resilience activities. We  recognize that MitFLG does not have the authority to compel other federal   agencies to comply with the recommendations developed as part of the  investment strategy. However, we believe creating a strategy that helps  guide federal decisions makers across the interagency group—including  recommendations to the executive and legislative branches of the federal  government on how to best prioritize federal resources aimed at  enhancing disaster resilience—would be consistent with MitFLG’s  purpose, which is to coordinate mitigation efforts across the federal  government. We also believe that as the interagency group established  expressly for this purpose, MitFLG is the most appropriate organizational  entity to undertake the creation of this strategy.
DHS stated that the Chair of MitFLG will take the following three steps to  address the recommendation:  1.  brief MitFLG members on our recommendation and FEMA’s response  on behalf of MitFLG and call for work group members from the  interagency group for support by August 31, 2015;  2.  form a working group to develop the scope, coordinate the effort, and  develop a draft of the recommendations for MitFLG to consider by  September 30, 2016; and,  3.  finalize a deliverable through MitFLG review and coordination with the  interagency membership by August 30, 2017.
DHS stated that the estimated completion date for implementing this  recommendation is September 30, 2017. These actions could address  our recommendation and help the nation prioritize federal resources to  further enhance national resilience against future disasters. We will  continue to monitor the efforts to implement our recommendations.
We will send copies of this report to the Secretaries of Homeland  Security, Housing and Urban Development, Defense, Transportation; the  FEMA Administrator; and appropriate congressional committees.
If you or your staff have any questions about this report, please contact  me at (404) 679-1875 or curriec@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. Other key contributors to this report are listed in  appendix IV.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report examines (1) how states and localities in the Sandy-affected  area have used federal funds to help enhance disaster resilience, (2) the  extent to which state officials report being able to use federal programs to  maximize resilience-building during disaster recovery, and (3) actions the  federal government has taken to promote disaster resilience in the  recovery effort and what, if any, improvements could be made for future  large-scale disasters.
To determine how states and localities used federal funds to enhance  disaster resilience during the Hurricane Sandy disaster recovery effort,  we reviewed program documentation—such as grant guidance and  federal rules—and discussed program purposes with key agency officials  to determine whether and how administered programs and activities  facilitate community and regional resilience as part of rebuilding.  We  obtained information on appropriations from the Disaster Relief  Appropriations Act, 2013 (Sandy Supplemental), and the information  related to the purposes of programs and activities from the Sandy  Supplemental and federal agency documents. We focused on describing  five federal programs that have the ability to support resilience-building  efforts and that are administered by four federal agencies that received  92 percent of the Sandy Supplemental. We collected and analyzed  information from the District of Columbia, New York City, and each of the  12 states that had a major disaster declaration about the types of  resilience-building projects for which they used federal funds to enhance  resilience as part of the Hurricane Sandy recovery effort. We also  reviewed state hazard mitigation plans, local hazard mitigation plans and  guidance, and information regarding large-scale state projects from  Federal Emergency Management Agency (FEMA) headquarters, FEMA’s  Sandy Recovery Office, and state officials. During a site visit to New  Jersey, 1 of the 2 states that sustained the most damage, we also toured  damaged areas and projects in progress to observe and discuss planned  resilience-building efforts.
To determine to what extent selected state officials reported being able to  use federal programs to maximize resilience as part of the Sandy  recovery effort we obtained information about the resilience-building  efforts from data requests, structured interviews, and a follow-up survey  we conducted with State Hazard Mitigation Officers and other  knowledgeable officials in the 13 states that received presidential major  disaster declarations in the wake of Hurricane Sandy. In seven of the  interviews, State Hazard Mitigation Officers were joined by their state  counterparts or supervisors in state emergency management  departments with responsibility for managing other aspects of recovery  efforts. We also administered the structured interview and survey with  officials from New York City’s Office of Recovery and Resiliency, which  administered some streams of relevant federal funds—including FEMA  Hazard Mitigation Grant Program (HMGP) and Public Assistance (PA)  and the Department of Housing and Urban Development (HUD)  Community Development Block Grant-Disaster Recovery (CDBG-DR)— and oversees strategic planning for resilience efforts, the New York  Governor’s Office of Storm Recovery, which is largely responsible for  administering FEMA HMGP and HUD CDBG-DR funds, and the New  Jersey Governor’s Office of Recovery and Rebuilding, which coordinates  the state’s recovery effort, including overseeing resilience priorities. In  New York and New Jersey the governors’ offices collaborated with the  state emergency management offices (particularly the State Hazard  Mitigation Officers) to complete the survey.
In the data calls, we requested that State Hazard Mitigation Officers, in  coordination with other knowledgeable state officials, identify the names  of federal and state funding streams that were available for hazard  mitigation projects and those that were used for projects during the Sandy  recovery. We also requested a comprehensive list, or selected examples,  of hazard mitigation projects that their states had planned or underway.
We developed structured interview questions to collect information about  officials’ experiences using federal funding to enhance resilience in  recovering from Hurricane Sandy and other disasters that occurred since  2011, and successes or challenges states have encountered in trying to  rebuild resilience. We chose 2011 because the Sandy Supplemental  directed these funds to be available for areas most impacted and  distressed as a result of Presidentially-declared major disasters from  2011-2013.interviews, we had open-ended, unstructured interviews with three State  Hazard Mitigation Officers from 3 states outside the Sandy-affected  area—Florida, Iowa, and Tennessee—and multiple professional  associations about what kind of information was available and about  specific terminology within the field. We then pretested the structured  interview protocol with State Hazard Mitigation Officers from three Sandy- affected states. We conducted these pretests to ensure the questions  were clear and unbiased and that the questionnaire did not place an  undue burden on respondents. An independent reviewer within GAO also  reviewed a draft of the questionnaire prior to the administration of the  interviews. We made appropriate revisions to the content and format of  the questionnaire based on the pretests and independent review.
To begin development of the data calls and structured  We conducted the structured interviews in-person and via telephone from  August 26, 2014 to December 2, 2014. The interviews were primarily  conducted in person, with the exception of interviews with officials from 3  states because of scheduling conflicts. On the basis of a content analysis  of the information gathered in the structured interviews, we developed  close-ended questions for the follow-up survey where we asked officials  whether their states experienced specific challenges identified during the  interviews, and the extent to which these challenges affected states’  ability to maximize federal support for enhancing disaster resilience.
We conducted survey pretests with State Hazard Mitigation Officers from  2 states and governor’s office officials from 1 state. An independent  reviewer within GAO also reviewed a draft of the questionnaire prior to  administration of the survey. We made appropriate revisions to the  content and format of the questions based on feedback from the pretests  and independent review. The final questionnaire is in appendix III. We  sent the survey questionnaire by email in an attached Microsoft Word  form that respondents could return electronically after completing it. When  we completed the final survey questions and format, we sent the  questionnaire with a cover letter on March 4, 2015. On March 13, 2015,  we sent a reminder email to everyone who had not responded, attaching  an additional copy of the questionnaire. Following this reminder, we  conducted follow-up with participants on an individual basis. Completed  questionnaires were accepted until April 29, 2015. In all, we received  completed questionnaires from officials in 13 states and cities.
We also conducted five follow-up phone calls and one email exchange  with officials who responded to our survey. The purpose of these follow- ups was to clarify the answers of respondents in the case of (1) questions  that were left blank on the completed questionnaire, (2) multiple  responses being chosen for a single question, or (3) responses that  indicated that an item listed was not a challenge but also the challenge  had reduced their state’s ability to maximize resilience opportunities to  some extent. We adjusted the responses recorded on these officials’  questionnaires to reflect the clarifications made during these phone calls.
Because this was not a sample survey, it has no sampling errors.  However, the practical difficulties of conducting any survey may introduce  errors, commonly referred to as nonsampling errors. For example,  difficulties in interpreting a particular question, sources of information  available to respondents, or entering data into a database or analyzing  them can introduce unwanted variability into the survey results. We took  steps in developing the questionnaire, collecting the data, and analyzing  them to minimize such nonsampling errors. For example, we performed  pretesting and obtained internal review with independent survey experts.  In addition, an independent analyst checked the database used to collect  survey responses against the questionnaires completed by survey  respondents to ensure that all data were recorded correctly.
The structured interviews and surveys were administered in a selected  group of states and are not generalizable to the nation as a whole.  However, they represent the entire population of states involved in the  recovery from Hurricane Sandy. The states span 4 of 10 FEMA regions  and multiple geographic regions of the eastern United States. In  interviews and the follow-up survey we discussed the Hurricane Sandy  recovery effort, as well as recovery from smaller disasters that occurred  since 2011. Accordingly, the results of the interviews and surveys offer  insights into the recent experiences nonfederal users have had when  building resilience during disaster recovery. The overall response rate for  the surveys is 92 percent.
We compared information we learned from interviews with federal, state,  and local officials and from federal documents with the goals stated in the  National Disaster Recovery Framework (NDRF) and National Mitigation  Framework (NMF). Specifically, these policies call for the government to  integrate hazard mitigation and risk reduction opportunities into all major  decisions and reinvestments during the recovery process and to  capitalize on opportunities during the recovery process to further reduce  vulnerability.
To determine what actions the federal government took to promote  resilience in the Hurricane Sandy recovery effort, and what, if any,  improvements could be made for future large-scale disasters, we  reviewed federal statutes, regulations, executive orders, and federal  studies related to hazard mitigation and resilience. These included the  Disaster Relief Appropriations Act of 2013 (the Sandy Supplemental),  the Sandy Recovery Improvement Act of 2013 (SRIA), the President’s  Executive Order (EO) 13632—Establishing the Hurricane Sandy  Rebuilding Task Force, and the 2013 Hurricane Sandy Rebuilding  Strategy: Stronger Communities, A Resilient Region. We also analyzed  the recommendations of the Hurricane Sandy Task Force report that were  intended to help facilitate or remove obstacles to resilience.  We obtained  information about the status of implementing the recommendations in the  task force report from FEMA, HUD and Transportation (DOT) and the  U.S. Army Corps of Engineers (USACE) via documents and interviews  with officials involved in the Hurricane Sandy recovery. In addition, we  obtained information on the status of implementing resilience-building- related provisions of SRIA from FEMA officials. We interviewed officials  representing HUD, FEMA, and the interdepartmental Mitigation  Framework Leadership Group (MitFLG) to discuss the challenges state  officials reported to us and challenges experienced at the federal level. As  evidenced by the various recipients of federal appropriations in the Sandy  Supplemental, both disaster recovery and building disaster resilience to  reduce the federal fiscal exposure to future disaster losses is a mission  that cuts across federal departments. Therefore, we compared the  challenges reported by state and federal officials with elements of a  national strategy that we have previously recommended to help support  such efforts.
We conducted this performance audit from November 2013 to July 2015  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: Status Updates on Selected Recommendations from the Hurricane Sandy Rebuilding Task Force
paragraphs: Executive Order (EO) 13632 on Establishing the Hurricane Sandy  Rebuilding Task Force established and charged the Hurricane Sandy  Rebuilding Task Force with identifying actions that federal agencies can  take to enhance resilient rebuilding. The task force developed the  Hurricane Sandy Task Force Rebuilding Strategy, which consists of 69  recommendations to federal agencies and working groups. We identified  19 recommendations that had aspects of resilience-rebuilding, as  described by EO 13632, and had at least one of the four agencies we  chose to review as part of the scope of this report—Department of  Transportation (DOT), Federal Emergency Management Agency (FEMA),  Department of Housing and Urban Development (HUD), and U.S. Army  Corps of Engineers (USACE)—designated as a lead or supporting  agency for implementing the recommendation. The table below reflects  the status and progress of the implementation of the recommendations,  as reported in the Rebuilding Strategy, subsequent progress updates  (spring and fall 2014), and interviews with agency officials.
section_title: Appendix III: GAO Follow-Up Questionnaire for State Hazard Mitigation Officers Related to Hurricane Sandy Recovery and Resilience
section_title: Appendix IV: Comments from the Department of Homeland Security
section_title: Appendix V: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Kathryn Godfrey (Assistant  Director), Dorian Dunbar, Melissa Duong, Serena Epstein, Lorraine  Ettaro, Eric Hauswirth, R. Denton Herring, and Tracey King made  significant contributions to this report. Also contributing to this report were  Joel Aldape, Claudia Becker, Andrew Brown, Alicia Cackley, Martha  Chow, Steve Cohen, Catherine Colwell, Roshni Dave, Katherine Davis,  Peter Del Toro, Anne-Marie Fennell, Jose (Alfredo) Gomez, Joah  Iannotta, Valerie Kasindi, Stuart (Stu) Kaufman, Chris Keisling, Monica  Kelly, Stephen Lord, Phillip McIntyre, Susan Offutt, Anthony (Tony)  Pordes, Brenda Rabinowitz, Oliver Richard, Tovah Rom, Michelle Sager,  Janet Temko-Blinder, Joseph Thompson, and David Wise.