Wildfire Disasters: FEMA Could Take Additional Actions to Address Unique Response and Recovery Challenges
Released: 2019-10-09T00:00:00

Letter

Background

FEMA’s Role in Providing Assistance During and After Wildfires

Fire Management Assistance Grants

The activities and resources required to suppress wildfires generally belong to the states and federal agencies with land management missions, such as the U.S. Forest Service and four bureaus (Bureau of Land Management, Bureau of Indian Affairs, National Park Service, and U.S. Fish and Wildlife Service) within the U.S. Department of the Interior. FEMA can provide reimbursement to help support wildfire suppression (e.g., labor costs for overtime or seasonal personnel involved in fire suppression activities). When a wildfire burns on nonfederal lands and threatens to become a major disaster, a state governor or governor’s representative may request federal assistance via a Fire Management Assistance Grant (FMAG) administered by FEMA. While the fire is burning, a governor’s office can submit a verbal request for an FMAG to the designated FEMA regional office, followed within 14 days by a formal written request. The regional administrator then either approves or denies the request after consulting with relevant officials from the U.S. Forest Service or bureaus within the U.S. Department of the Interior about technical aspects of the fire. Eligible FMAG costs include, among other things, equipment and supplies, labor costs, travel and per diem, temporary repairs of damage caused by firefighting activities, mobilization and demobilization of resources, and limited costs of pre-positioning fire prevention or suppression resources.

From fiscal years 2009 through 2018, FEMA awarded 374 FMAGs totaling $952,318,049. The average FMAG during this timeframe was about $2.5 million. The state of California received the majority of those grant funds—over $543 million. Figure 1 below illustrates the states that received FMAGs during this 10 year period, figure 2 provides annual FMAG totals, and figure 3 provides a breakout of the dollars distributed by state for this same 10 year period.

If a wildfire increases in size and intensity in a manner that overwhelms the ability of state, tribal, territorial or local governments to respond and recover effectively, a state or tribal government can request and the President can approve a major disaster declaration, as with other types of disasters (e.g., a hurricane or flood). A disaster declaration is the primary mechanism by which the federal government gets involved in funding and coordinating response and recovery activities. Under the National Response Framework, the Department of Homeland Security (DHS) is the federal department with primary responsibility for coordinating disaster response, and within DHS, FEMA has lead responsibility. From fiscal years 2009 through 2018, a total of 19 major disasters were declared as a result of wildfires. Figure 4 shows the number and locations of these major disaster declarations.

Once a major disaster is declared, FEMA can provide funds for response and recovery efforts through the Disaster Relief Fund and coordinate other federal support through the National Response Framework’s 14 Emergency Support Functions. Federal assistance following a major disaster declaration includes the following: Individual Assistance: FEMA’s Individual Assistance programs provide assistance directly to individuals and households, as well as state, local, tribal, and territorial governments to support individual survivors. This assistance covers necessary expenditures and serious needs that cannot be met through insurance or low-interest loans, such as temporary housing assistance, counseling, unemployment compensation, or medical expenses. See appendix I for a further description of FEMA’s Individual Assistance program.

Public Assistance: FEMA’s Public Assistance program provides supplemental federal disaster grant assistance to state, local, tribal, and territorial governments and certain types of private nonprofit organizations for debris removal, emergency protective measures, and the restoration of disaster-damaged, publicly-owned facilities and the facilities of certain private nonprofit organizations. The eligibility rules outline the types of damage that can be reimbursed by the federal government and steps that federal, state, and local governments must take in order to document eligibility. If the debris on private property is determined to be so widespread that it threatens the health, safety, or economic recovery of the community, FEMA may determine that debris removal from private property, including contaminated soil, is eligible for reimbursement under the Public Assistance program. An applicant (a state, territorial, or tribal government) may contract for debris removal. Alternatively, if an applicant lacks the capability to perform or contract for debris removal, the applicant may request that the federal government perform the work. In such cases, FEMA may task another federal agency, typically the U.S. Army Corps of Engineers (USACE), to perform or contract the work by issuing a mission assignment (see description below). See appendix I for a further description of FEMA’s Public Assistance program.

Mission Assignment to Other Agencies: FEMA can fulfill disaster response needs through mission assignments—work orders it issues to another federal agency to provide a service or other response need. For example, FEMA may request medical teams from the Department of Health and Human Services and logistical support from the Department of Defense.

Hazard Mitigation Grant Program: This program is designed to improve disaster resilience—the ability to prepare and plan for, absorb, recover from, and more successfully adapt to disasters—during recovery. The program funds a wide range of projects, such as use of non-combustible materials on new and existing homes to mitigate risk from future wildfires, adding shutters to windows to prevent future damage from hurricane winds and rains, and rebuilding culverts in drainage ditches to prevent future flooding damage.

Table 2 below shows money obligated for Individual Assistance, Public Assistance, mitigation efforts, operations (including mission assignments), and administrative costs for the 19 major disaster declarations resulting from wildfires from fiscal years 2009 through 2018.

Other Federal Roles and Responsibilities for Wildfires

The U.S. Forest Service within the Department of Agriculture and the Bureau of Indian Affairs, Bureau of Land Management, U.S. Fish and Wildlife Service, and National Park Service within the Department of the Interior, are responsible for managing wildfires on federal lands. Wildfire management consists of three primary components: 1. Preparedness involves acquiring and positioning firefighting assets. 2. Suppression involves selecting among strategies to extinguish or contain a fire, with the aim of protecting firefighters and public safety and using the minimum resources necessary. 3. Fuels Reduction involves acting in advance of wildfires to manage vegetation with the aim of reducing the intensity, severity, or negative effects of a wildfire. We are currently reviewing federal fuel reduction efforts, and how those efforts consider community protection, and plan to issue a report on the subject later this year.

State Efforts and Assistance Available for Fighting Wildfires

State forestry agencies and other nonfederal entities—including tribal, county, city, and rural fire departments—have primary responsibility for managing wildfires on nonfederal lands, and share responsibility for protecting homes and other private structures. When a wildfire occurs on nonfederal lands and begins to exceed the state or local entity’s ability to effectively respond to the wildfire, the state or local entity may seek assistance from neighboring jurisdictions, typically through prescribed mutual aid agreements. For example, during wildfires in California in October and December of 2017, the California Governor’s Office of Emergency Services used the California fire and rescue and law enforcement mutual aid systems, along with the national Emergency Management Assistance Compact to mobilize and organize a large number of emergency services. In total, according to California Governor’s Office of Emergency Services, over 400 state and local government and 200 out-of-state fire departments sent engines, crews, and other assets to assist the local firefighting efforts. When a state or local jurisdiction needs further firefighting assistance, it may request additional support through Geographic Area Coordination Centers overseen by the National Interagency Fire Center. Once a Geographic Area Coordination Center has exhausted the resources it can provide, it can turn to the National Interagency Coordination Center within the National Interagency Fire Center for further assistance.

FEMA Provided Assistance to Help Wildfire-Affected State and Local Jurisdictions Consistent with Its Role in the National Response and Recovery Frameworks

For wildfire disaster declarations from 2015 to 2018, FEMA provided a variety of assistance to state and local emergency management officials consistent with roles and responsibilities in the National Response Framework and National Disaster Recovery Framework. Specifically, FEMA helped these jurisdictions by reimbursing some fire suppression costs, supporting state-led efforts to coordinate the response and provide for the immediate needs of displaced survivors, and helping localities plan and execute recovery. FEMA has obligated over $2.4 billion to assist in response to and recovery from these disasters to date.

As previously discussed, although states and other federal agencies have primary responsibility for fire suppression, some state and local fire suppression costs are eligible for reimbursement through FMAGs. Most wildfire-affected states and localities in our scope received this kind of fire suppression support from FEMA initially in the form of the FMAGs. As the fires ultimately led to major disaster declarations, any funding that FEMA would have provided through the FMAGs were ultimately provided under Public Assistance as part of the declaration.

To support state-led response and provide for the immediate needs of displaced survivors, FEMA deployed staff to assist in state Emergency Operations Centers and secured needed resources for mass care—such as cots to help with temporary sheltering, according to state officials. In addition, FEMA assigned federal agencies to perform various missions to help with disaster response. For example, the Environmental Protection Agency provided hazardous material cleanup of damaged properties, and USACE provided public works services, such as contracting for debris removal.

As response activities continued and recovery began, FEMA and the state emergency management agencies established Joint Field Offices, which are temporary field offices established to coordinate federal and state efforts in disaster response and recovery, and provided resources to help individual disaster survivors with community services and housing needs. For example, following wildfires in November 2018—including the Camp Fire in Butte County—FEMA provided over $55 million to survivors to reimburse them for the cost of temporary lodging and rentals after their homes were destroyed. In addition, FEMA provided funding and support to local jurisdictions to help address community infrastructure needs. For example, FEMA obligated money to pay for wildfire debris removal from public property as well as from private property, given the widespread effect on the community of toxic fire debris.

Also to support recovery, in coordination with state and local entities, FEMA established and staffed Disaster Recovery Centers, which are facilities or mobile offices where survivors can go for information about FEMA programs or other disaster assistance programs. Representatives from the relevant state agencies, FEMA, U.S. Small Business Administration, volunteer agencies, and other agencies were at the centers to answer questions about and help survivors apply for disaster assistance and low-interest disaster loans for homeowners, renters, and businesses.

Finally, to assist local jurisdictions with longer-term recovery, FEMA provided assistance to some locally-led long-term recovery activities designed to address housing and other survivor needs in the community. Table 3 shows the amount of assistance FEMA provided for each of the six major disasters that we reviewed, and Appendix II provides a more detailed breakdown of each major disaster, including a map of each disaster, the number of structures that were destroyed, and mission assignment data.

Multiple Jurisdictions Reported FEMA Practices that Aided in Wildfire Response and Recovery, But also Experienced Challenges

State and local officials we spoke with reported practices that aided in wildfire response and recovery and also experienced challenges that arose in multiple jurisdictions across different disasters.

Jurisdictions Noted Specific Actions that Aided Response and Recovery Efforts

FEMA and State Collaboration

When asked what worked well, officials from three out of the six California counties told us that FEMA and the California Governor’s Office of Emergency Services collaborated effectively during response and recovery efforts. For example, one of the three counties reported that when posing questions or concerns to the California Governor’s Office of Emergency Services, they were able to quickly obtain answers or further information and get help navigating complex issues. As we reported in 2018, according to officials in the California Governor’s Office of Emergency Services and FEMA, they have developed a strong relationship with each other over time, which helps both agencies deliver consistent, unified information to stakeholders and disaster survivors.

Services Provided to Disaster Survivors

Local officials also praised FEMA’s role in helping to set up and operate Disaster Recovery Centers. Officials in four of the six California counties that we interviewed noted that FEMA was quick to send staff to assist local jurisdiction staff and disaster survivors at the facilities established to provide assistance, such as Local Assistance Centers (generally activated by the county in the immediate wake of a disaster to provide government services to survivors) and Disaster Recovery Centers established by FEMA. For example, one of these counties noted that FEMA had staff available at their Local Assistance Center to support requests for Individual Assistance and other items shortly after the disaster was declared, and the county received positive feedback from the public about the varied types of support provided by experienced staff at their Local Assistance Center.

Officials in one of the counties mentioned above, as well as FEMA officials, cited as good practices efforts to bring together local and state providers of governmental services to provide a variety of assistance in one place. For example, FEMA credited one county for their efforts in partnering with a local mental health service provider to offer mental health counseling on site at a Disaster Recovery Center, as opposed to referring individuals to such services off site.

Similarly, one Disaster Recovery Center we visited in California included representation from a number of different state agencies, such as the state’s contractors’ licensing board, insurance regulators, department of employment opportunities, and franchise tax board. Officials explained that being able to access a variety of state services in a Disaster Recovery Center can be particularly helpful for fire survivors, as they may have evacuated their homes with very little notice and lost all their identifying documentation to the fire.

Jurisdictions Experienced a Number of Response and Recovery Challenges

State and county officials described challenges that were present in several of the wildfire disaster declarations that we reviewed. Some of these challenges—such as a complex Public Assistance application process or FEMA staff turnover—are not specific to wildfires and could also affect recovery efforts after a hurricane, flood, or other natural disaster. Some challenges were more specific to and further complicated by the nature of wildfire disasters. These challenges include the complexity and scale of fire debris removal, shortage of temporary housing for wildfire survivors, and lack of local experience dealing with the magnitude of the wildfires encountered in 2017 and 2018.

Complexity and Timeframes for FEMA Public Assistance Applications

Officials in three of the seven counties we met with said that the onerous and confusing documentation required when applying for Public Assistance grants was a challenge. For example, an official from one county told us that the Public Assistance guidance in effect at the time his county was recovering from disaster contained conflicting information, though he believed this issue has since been resolved.

Officials in two counties also described difficulty meeting the deadlines for application submission, especially while managing the other demands of disaster response and recovery. We have previously reported on challenges with FEMA’s administration of the Public Assistance program, including effectively overseeing and staffing the program, among other things. Officials from FEMA’s Public Assistance Division acknowledged that the complexity of the program has been a challenge for local officials in recent years. The officials pointed to the development of a new Public Assistance delivery model as the key initiative to address these challenges. This new delivery model, which includes a new information portal designed to improve local officials’ ability to upload and submit information, was intended to clarify program requirements, improve operations, and respond to previously-identified challenges, according to FEMA officials. FEMA introduced the new model in California during the recovery phase of the 2017 wildfires.

Officials from two of the selected counties stated that the new information portal eased the process of submitting documentation for FEMA review. In 2017, we reported on the historical challenges with FEMA’s Public Assistance program and identified additional challenges with the roll-out of the new delivery model, including the need to determine its staffing needs for supporting rollout of the system and strengthen controls over the information system being used. California officials we spoke with also noted that in order for the new delivery model to be used efficiently, it would be helpful for FEMA to provide additional training to stakeholders who use the system. According to FEMA officials, FEMA provided a number of training sessions on the new model to California stakeholders between August 2017 and April 2019.

Frequent Turnover of FEMA Staff

Officials in three of the seven selected counties told us that frequent rotations of FEMA staff during disaster response and recovery was disruptive. For example, after working with state and local officials following a disaster, the rotations of FEMA staff resulted in having to re- share information that was already provided to FEMA, as well as inconsistent advice or interpretation of FEMA guidelines. FEMA officials acknowledged that ensuring continuity following staff turnover has long been an issue in multiple complex disaster environments. They noted a number of reasons why a staff member in a position might turn over. For example, according to FEMA officials, the disasters in 2017, including Hurricanes Harvey, Irma, and Maria, as well as the California wildfires, required FEMA management to redeploy response personnel from one disaster to the next. We have reported on multiple FEMA workforce challenges in prior work and continue to observe workforce challenges in our ongoing work. We are currently reviewing how FEMA deploys and trains staff to meet disaster mission needs and plan to report early in 2020.

Complexity and Scale of Wildfire Debris Removal

Debris removal is an important first step in the disaster recovery process, allowing communities to expedite the recovery process by restoring accessibility to public services and space, while ensuring public health and safety in the aftermath of a disaster. Debris removal posed several challenges for state and local jurisdictions affected by the wildfires. Wildfires typically leave no remaining structure, and the resulting ash contains contaminants that must be carefully removed, wrapped, and disposed of before survivors can move back to their properties. This can make the wildfire debris removal process costlier and more complicated than for other types of disaster debris. California’s Department of Resources, Recycling, and Recovery typically handles debris removal after local disasters in the state, but it did not have the capacity to handle the high volume of debris caused by the 2017 Northern California wildfires. As a result, the state asked FEMA to assign USACE with the debris removal mission.

According to local officials, there was some confusion over how much contaminated soil should be removed from some properties. Specifically, in some cases, USACE removed more soil than necessary at home sites in an attempt to “scrape” the soil deeply enough to remove all possible contaminants at the site; however, this did not take into account that some contaminants, such as arsenic, occur naturally in the soil. As a result, some property owners were left with large over-excavated pits on their property that needed to be filled in before rebuilding could occur. Figure 5 shows a property site that, according to local officials, had been excavated below the foundation of the home and thus needed to be refilled with soil, complicating the rebuilding effort. In addition, officials from one county stated that USACE staff rotations made it difficult for state and local officials to communicate debris removal options clearly both internally and to the public, leading to confusion among some survivors about their best options for debris removal.

In 2018 and 2019, we reported on issues with contracting for wildfire debris removal. We found that USACE’s debris removal contracts, while broad enough to cover any type of debris, had been used primarily to manage hurricane debris removal and did not address issues posed by wildfire debris removal. We also found that miscommunication at the federal level resulted in differing expectations between USACE and state and local officials about debris removal work to be performed, such as the types of structures to be removed from private property and acceptable soil contamination levels. According to USACE officials, they relied on FEMA to manage communication with states and localities and to identify and manage expectations about the scope of work to be performed. We recommended, among other things, that FEMA take the lead to work together with USACE to revise the mission assignment policy and related guidance to better incorporate consideration of contracting needs and to ensure clarity of contracting-related coordination responsibilities. DHS concurred with this recommendation and reported that it will take steps— such as development of mission assignment project management tools and training for mission assignment work—to implement it.

Shortage of Temporary Housing for Wildfire Survivors

According to DHS’s 2017 National Preparedness Report, providing effective and affordable temporary housing for disaster survivors has been a longstanding and continuing challenge. Wildfires pose an additional challenge because in contrast to disasters such as hurricanes or floods where there may be a substantial portion of a home left standing, and property may be habitable after the most dangerous debris is removed, wildfires generally destroy entire structures and leave a pile of contaminated debris and soil. This kind of damage requires a lengthier clean-up and necessarily precludes survivors from occupying the property until state and local officials declare the lot safe for habitation.

In the meantime, one of FEMA’s responsibilities under the Mass Care, Emergency Assistance, Temporary Housing and Human Services Emergency Support Function is to help displaced disaster survivors with access to temporary housing. This has posed challenges for some of the counties we spoke with, most notably in select Northern California communities. In particular, officials in two California counties noted that vacancy rates are very low in these areas, and there were few places to house survivors who were either waiting to rebuild on their property or had been living in rental properties that were destroyed. In addition, in one California county there have been a limited number of potential sites available (such as commercial parks or group sites) to place transportable temporary housing units. According to FEMA, several factors limited the number of commercial or group sites available for such housing units, including limited space for the housing units, contaminated utilities, and challenges with local jurisdictions responsible for deciding whether and where to place group sites.

According to FEMA officials, the nature of fire debris affects the array of post-disaster housing options that FEMA can offer through its Individual Assistance program. For example, although FEMA can provide replacement assistance for destroyed homes and repair assistance for homes with damage that can be repaired, the complete destruction of homes due to fires significantly lengthens the recovery processes. Rental assistance and lodging reimbursement are limited by lack of access to rental properties, and the use of manufactured housing units is limited by lack of group sites that meet requirements, including adequate space for such units and access to utilities (e.g., potable water not contaminated by fire damage). See Appendix I for more information on this program.

FEMA officials acknowledged that providing housing for survivors has long been a challenge for the agency. They also acknowledged that several of FEMA’s housing tools are less relevant to wildfires versus other disasters (as discussed above). According to FEMA, the agency is currently reviewing various aspects of its housing mission to better identify ways to address some of these challenges.

Lack of Experience with Large- Scale Wildfires

Officials from two of the counties we spoke with said that their lack of experience in response to and recovery from wildfires of the magnitudes encountered was very challenging. Officials from one of those counties stated that they did not have the knowledge or skill-set needed at the local level to best identify response and recovery needs and relied heavily on FEMA and California’s Governor’s Office of Emergency Services for resources and training in these areas.

Officials from another county stated that neither they nor FEMA were accustomed to the level of destruction in a rural area, which created challenges identifying resources and processes to remove damaged trees from private property, storing the volume of downed trees, and maintaining the few roads available for hauling debris.

Officials from another county in California described being unprepared when they were tasked with collecting duplicate payments for private property debris removal after survivors received their insurance benefits. Residents who participated in the private property debris removal program who were paid out of FEMA’s Public Assistance program, and subsequently also received an insurance benefit for debris removal, were required to repay the federal government for the duplicate benefit. According to these county officials, they were not aware that collection would be their responsibility until about 2 years after the initial debris removal took place. The officials noted that the administrative burden for identifying the affected homeowners and the amount owed and then collecting the payments was significant, and taxed their administrative capacity. They said they wished they had been aware sooner that they would have to absorb this duty, so they could put systems in place. According to FEMA and state officials, however, these requirements were included in FEMA’s Public Assistance Program and Policy Guide, which states that local governments are responsible for implementing private property debris removal, including the requirement to collect and reimburse FEMA for any duplicate benefits. Nevertheless, the confusion described by the county government illustrates the difficulty jurisdictional officials with little previous wildfire experience can have navigating complex program rules while simultaneously confronting the disaster aftermath.

FEMA Has Identified Lessons Learned from 2017 Wildfires but Could Further Benefit from a Comprehensive Assessment of Its Operations, Policies, and Procedures

FEMA Has Prepared an After-Action Report for 2017 California Wildfires

In June 2019, FEMA Region IX—which provides disaster assistance in California—finalized the after-action report for the October and December 2017 wildfire disasters in Northern and Southern California. FEMA’s 2017 wildfire after-action report offered response and recovery lessons learned from both the challenges identified and successful practices. Some, but not all, of these were mirrored in our interviews with California jurisdictions that were affected by recent wildfires. Among its findings, the 2017 wildfire after-action report identified several areas for improvement. For example, FEMA’s immediate activation of the Transitional Sheltering Assistance program and lack of a unified information system to track applicants’ eligibility for all Individual Assistance programs at the time of the wildfires resulted, in some instances, in applicants receiving sheltering benefits inappropriately (i.e., receiving Transitional Sheltering Assistance benefits despite their residence being undamaged). One potential action to address this challenge identified in the report was to add information on Transitional Sheltering Assistance program applicants into the database that FEMA uses to track disaster information to ensure those applicants have access to all benefits and reduce the potential for duplication. FEMA officials have stated that since the 2017 wildfires, policy changes have been made to address this issue, including adding Transitional Sheltering Assistance program applicant data to the information system used to track eligibility for all Individual Assistance programs.

In addition, FEMA reported that the typical contracts USACE had in place for debris removal were not designed to address the nature (i.e., fire- related debris) and scope of work required, particularly with respect to private property debris removal. The agencies worked together to rapidly scope the statements of work for the debris removal contracts to provide services to survivors, but FEMA ultimately found that the contract requirements lacked detail and clarity, resulting in additional costs. USACE prepared its own after-action report after the 2017 wildfires, which also identified challenges with the scope of its debris removal contracts and the mission assignment task orders, and planned to incorporate lessons learned in future debris removal contracts.

According to FEMA Region IX officials, many of the issues regarding debris removal stemmed from not having documented processes in place to govern wildfire debris removal specifically. In its after-action report, FEMA identified potential actions to address these challenges—such as developing standard operating procedures in coordination with USACE for fire debris removal—to correct these and other identified areas for improvement. According to USACE officials, FEMA subsequently provided funds through a 2018 wildfire disaster declaration to USACE to develop such standard operating procedures. USACE officials told us they had shared these procedures with FEMA and stated that the procedures will help guide future wildfire private property debris removal operations.

The 2017 after-action report also identified a number of strengths and best practices during 2017 wildfire response and recovery efforts in California. For example, the report noted that collaboration and pre- existing relationships between federal and state personnel helped to overcome knowledge gaps about certain programs and improved survivor outcomes (such as the placement of temporary housing units based on work done by an interagency task force). In addition, Facebook provided FEMA with pre- and post-disaster survivor locations (provided voluntarily by the survivor) that helped identify where survivors were located after the wildfires. Using this information, FEMA then worked with the state and private sector in order to help plan for short- and long-term housing solutions.

FEMA Could Improve Its Preparation for Potential Effects of Heightened Wildfire Risks by Comprehensively Assessing Its Operations, Policies, and Procedures

Standards for Internal Control in the Federal Government state that management should identify, analyze, and respond to significant changes that could impact its internal control system, which would include actions established through policies and procedures. Agency management, therefore, should analyze the effect of identified change on policies and procedures and revise such policies and procedures—and other elements of its internal control system—on a timely basis to maintain effectiveness.

The combination of back-to-back devastating wildfire seasons in California, overall upward trends in wildfire disaster declarations, and several factors that point to increased likelihood of severe wildfire activity in the future suggest a change that may have significant impacts on FEMA’s operating environment. As shown in figure 6, from 1953 to the present, the number of major disaster declarations from wildfires has increased in nearly every decade since 1950 and most dramatically in the last two decades. During Congressional testimony from March 2018, FEMA’s Region IX Administrator stated that fire season has changed from covering spring through early fall to a now year-round event, and that the unprecedented impacts from the 2017 wildfire season would linger for years to come.

Land use practices and climate trends increase the likelihood that severe and intense wildfires will affect people and communities. As we have described in previous reports, land use practices over the past century have reduced forest and rangeland ecosystems’ resilience to fire. Land use practices like fire suppression and timber harvesting have contributed to abnormally dense accumulations of vegetation. These accumulations can fuel uncharacteristically large or severe wildfires. At the same time, development occurring in and around wildlands—an area often called the wildland-urban interface—has increased, placing more people, businesses, and infrastructure at risk. The wildland-urban interface contains 46 million single-family homes, representing about 40 percent of single-family homes in the United States. According to the 2014 Quadrennial Fire Review, 60 percent of new homes built in the United States since 1990 were built in the wildland-urban interface. As the footprint of human activity and settlement into the wildland-urban interface expands, the risk of fire exposure to people and property is expected to increase further.

In addition, changing climate conditions, including drier conditions in certain parts of the country, have increased the length and severity of wildfire seasons, according to many scientists and researchers. For example, in the western United States, the average number of days in the fire season increased from approximately 200 in 1980 to approximately 300 in 2013, according to the 2014 Quadrennial Fire Review. According to the U.S. Global Change Research Program’s 2018 National Climate Assessment, warmer and drier conditions have led to a greater incidence of large forest fires (fires with an area greater than 386 square miles) in the western United States and Alaska, a trend expected to continue as climate warms and the fire season gets longer.

Despite these trends and projections, FEMA does not plan to comprehensively assess operations to determine whether and how policies and procedures might need to change to better respond to changing operational conditions. According to FEMA officials, they had not considered conducting this kind of review, because they believe their existing mechanisms—specifically after-action reporting, the continuous improvement process, and program specific mechanisms such as the Public Assistance Change Control Tool—will allow them to incorporate relevant lessons into policies and procedures.

According to FEMA officials, after a major disaster, FEMA’s standard practice is to identify areas for improvement and develop lessons learned that can improve FEMA planning and policy and support national preparedness by preparing an after-action report which is required by FEMA policy. FEMA has a continuous improvement program which serves as the overarching process by which it identifies and responds to operational lessons learned identified in after-action reporting. According to FEMA officials, FEMA headquarters reviews all completed after-action reports to identify any areas for improvement that may need to be addressed through changes in policies and procedures.

Although the continuous improvement process and its reliance on after- action reporting offers the opportunity to incorporate discrete lessons learned into select policies and procedures, there are some limitations in its ability to offer a comprehensive assessment of its internal controls in light of the strong potential that wildfire disasters will continue to increase. By its nature, after-action reporting captures select issues at a specific time and in a specific place, but it is not a dedicated effort to assess how various policies and procedures may need to be changed to better respond to changing operational conditions. For example, in our discussions with fire-affected jurisdictions, we noted that some programmatic or policy challenges were specific to or made more difficult by the nature of wildfires, such as the complexities of debris removal and difficult housing missions. A comprehensive review of internal controls, such as policies, procedures, and training, may shed light on aspects of FEMA’s operations—well tested over the years in hurricane and flood situations—that could be adapted for greater responsiveness to the wildfire environment, helping to ensure attention to a broad range of issues in addition to those that might be noticed in a specific time and place through after-action reporting.

In light of the potential for high-impact wildfires to become more frequent, a dedicated effort to comprehensively assess operations could help FEMA better ensure that its management controls—such as policies, procedures, and training—are as well designed as possible to respond to the unique challenges.

Conclusions

Devastating wildfires have exacted a large human and financial toll in recent years, with 159 lives lost and $2 billion obligated by FEMA in response during the major disasters of 2017 and 2018. FEMA has provided support personnel and resources to affected state and local jurisdictions to aid in wildfire response and recovery efforts. Given some reports of projected increase in risk from wildfires—as well as the challenges we have noted in providing housing, conducting debris removal operations, and other areas—comprehensively assessing agency operations in response to and recovery from wildfires to determine if any actions or changes to agency policies and procedures are needed could provide guidance or insight for communities that may be affected in the future. Comprehensively identifying, analyzing, and responding to the significant operating changes posed by wildfires, as recommended in internal control standards, could provide FEMA with an opportunity to better ensure the nation is ready to address the unique challenges posed by increased large-scale wildfires.

Recommendation for Executive Action

We recommend that the FEMA Administrator comprehensively assess operations to identify any additional updates to its management controls—such as policies, procedures, or training—that could enhance future response and recovery from large-scale and severe wildfires. (Recommendation 1)

Agency Comments and Our Evaluation

In August 2019, we requested comments on a draft of this report from the Departments of Agriculture, Defense, Interior, and Homeland Security. The Departments of Agriculture and Defense had no formal or technical comments. In September 2019, FEMA and the Department of the Interior provided technical comments, which we have incorporated as appropriate. In addition, DHS provided an official letter for inclusion in the report, which can be seen in appendix III, stating that it concurred with our recommendation. DHS’s letter describes a number of ongoing and planned actions that it plans to leverage in addressing our recommendation. These actions include, among other things, the use of sheltering and housing field teams to support states’ efforts to house disaster survivors; continued updates to direct housing guidance; developing guidance for the use of FEMA-issued, state-administered direct housing grants authorized by the Disaster Recovery Reform Act of 2018; and development of a project to analyze and improve capabilities and identify areas of innovation in response to wildfire disasters. DHS anticipates that these efforts will be put into effect by December 2020. We will continue to monitor DHS and FEMA’s efforts in addressing our recommendation.

We will send copies of the final report to the Secretaries of the departments mentioned above, 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.

Appendix I: Federal Emergency Management Agency (FEMA) Individual Assistance and Public Assistance Programs

FEMA’s Individual Assistance programs provide assistance directly to individuals and households, as well as state, local, tribal, and territorial governments to support individual survivors. This assistance covers necessary expenditures and serious needs that cannot be met through insurance or low-interest loans, such as temporary housing assistance, counseling, unemployment compensation, or medical expenses. FEMA provides this assistance through seven different programmatic areas, with a substantial amount of the assistance coming from the Individuals and Households Program.

The Individuals and Households Program provides financial assistance and direct services to eligible individuals and households who have uninsured or underinsured necessary expenses and serious needs. Individuals and Households Program assistance is intended to meet basic needs and supplement recovery efforts and is not a substitute for insurance. The Individuals and Households Program consists of two forms of assistance: Housing Assistance and Other Needs Assistance.

Housing Assistance: Housing assistance may be provided in the form of financial assistance, direct assistance, or a combination of the two. Financial assistance may include lodging expense reimbursement for time spent at hotels or other temporary lodging, rental assistance, and home repair or replacement assistance. Direct housing assistance may be provided when applicants are unable to use rental assistance due to a lack of available housing resources. This type of assistance may include the repair and lease of multi- family housing units—such as apartments—for temporary use by applicants, direct lease assistance, or the provision of transportable temporary housing units, such as recreation vehicles or manufactured housing units. Transportable temporary housing units can be placed on private sites, commercial sites or on group sites. Commercial sites are existing manufactured home sites with available pads that FEMA may lease. Group sites require additional approval when housing needs cannot be met by other direct temporary housing options. They may include publicly-owned land with adequate available utilities.

Other Needs Assistance: This consists of financial assistance for other expenses and serious needs caused by the disaster. Some Other Needs Assistance is only provided if an applicant does not qualify for a Small Business Administration disaster loan; this assistance would include personal property, moving and storage, and transportation assistance. Other types of Other Needs Assistance can be provided regardless of SBA loan qualification, including funeral, medical, dental, and child care assistance, and other miscellaneous items.

Mass Care and Emergency Assistance This program provides life-sustaining services to disaster survivors immediately before a potential incident, during the response phase, and during the beginning of post-disaster recovery. Services provided include sheltering, feeding, distribution of emergency supplies, support for individuals with disabilities and others with access and functional needs, reunification services for adults and children, support for household pets and service/assistance animals, and mass evacuee support.

This program provides supplemental federal financial assistance to states, territories, tribal governments, or private nonprofit entities in order to provide the services of a case manager to a disaster survivor. Through this service, a case manager assists a survivor with developing a disaster recovery plan for meeting his or her unmet needs.

Crisis Counseling Assistance and Training Program This program provides supplemental funding to eligible state, territorial, tribal, or local governments, and non-governmental organizations to assist disaster-impacted individuals and communities in recovering from the major disasters through the provision of community-based outreach and psycho-educational services.

This program provides legal aid to survivors who qualify as low-income through an agreement with the American Bar Association. The service is limited to cases that would not normally incur legal fees, such as assistance with insurance claims or recovery or reproduction of legal documents lost in the disaster.

This program provides unemployment benefits and re-employment assistance services to survivors under the responsibility of the U.S. Department of Labor. This assistance is only available to survivors who are not eligible for regular state unemployment insurance.

FEMA employs Voluntary Agency Liaisons who establish and maintain relationships with voluntary agencies active in response and recovery, coordinate with the National Voluntary Organizations Active in Disaster, provide guidance on donations, and act as subject matter experts in development of long term recovery groups with local community organizations, faith-based groups, and other voluntary organizations.

FEMA’s Public Assistance program provides supplemental federal disaster grant assistance to state, local, tribal, and territorial governments, and certain types of private nonprofit organizations for debris removal, emergency protective measures, and the restoration of disaster- damaged, publicly-owned facilities and the facilities of certain private nonprofit organizations. The Public Assistance program also encourages protection of these damaged facilities from future events by providing assistance for hazard mitigation measures. The program—which represents the largest share of federal aid from the Disaster Relief Fund—is administered through a partnership between FEMA and the state, tribal or territorial grantee, which provides funding to local or tribal entities who are the subrecipients of a Public Assistance grant award. The Public Assistance program funds both emergency work and permanent work.

Public Assistance for Emergency Work FEMA provides funding for emergency work such as emergency protective measures and debris removal that must be conducted immediately to save lives, protect public health and safety, protect improved property, or eliminate or lessen a threat of immediate additional damage. This assistance is divided into two categories, described below.

Debris Removal (Category A): Debris removal activities, such as clearance, removal, and disposal, are eligible if the removal is in the public interest based on whether the work eliminates immediate threats to lives, public health, and safety or of significant damage to improved public or private property; ensures economic recovery of the affected community to the benefit of the community at large; or mitigates risk to life and property by removing substantially damaged structures and associated structures. In limited circumstances, based on the severity of the impact of an incident, FEMA may determine that debris removal from private property is eligible under the Public Assistance Program. If debris on private property is so widespread that it threatens public health and safety or the economic recovery of the community, FEMA may provide Public Assistance funding for debris removal from private property.

Emergency Protective Measures (Category B): Emergency protective measures conducted before, during, and after an incident are eligible if the measures: eliminate or lessen immediate threats to lives, public health, or safety; or eliminate or lessen immediate threats of significant additional damage to improved public or private property in a cost-effective manner. Examples of such measures include transporting and pre-positioning equipment, flood fighting, supplies and commodities, evacuation and sheltering, child care, security, or searches to locate and recover human remains.

Public Assistance for Permanent Work Permanent Work is work required to restore a facility to its pre-disaster design (size and capacity) and function in accordance with applicable codes and standards. This assistance is divided into the five categories listed below:

Roads and Bridges (Category C)

Water Control Facilities (Category D)

Buildings and Equipment (Category E)

Utilities (Category F)

Parks, Recreational, Other (Category G)

Appendix II: Information on Major Disasters Resulting from Wildfires, 2015 through 2018

Below are details on the six wildfire disasters selected for our review and the support the Federal Emergency Management Agency (FEMA) provided under the major disaster declarations.

Northern California Wildfires, September 2015

On September 9, 2015, the Butte Fire began burning across Calaveras County, and on September 12, 2015, the Valley Fire began burning across Lake County. FEMA subsequently approved a Fire Management Assistance Grant (FMAG) for the Butte Fire on September 10, 2015, and an FMAG for the Valley Fire on September 12, 2015.

On September 22, 2015, the President issued a major disaster declaration at the request of the state for Lake County, which was ultimately expanded to include Calaveras County. On September 28, 2015, FEMA—in collaboration with the state and counties—opened two Disaster Recovery Centers in Calaveras and Lake Counties, and on October 2, 2015, FEMA opened a third Disaster Recovery Center in Lake County.

In total, the Valley and Butte Fires burned 146,935 acres, destroyed 2,876 structures, and resulted in 6 deaths. See figure 7 for a map of the fire locations, and tables 4 and 5 for data on FEMA’s mission assignments, Individual Assistance, and Public Assistance support.

East Tennessee Wildfires, November 2016

On November 28 2016, strong winds pushed a wildfire—named the Chimney Tops 2 fire—beyond the boundaries of the Great Smoky Mountains National Park and into the surrounding wildland urban interface. The fire primarily spread into Sevier County, Tennessee, which includes the cities of Gatlinburg and Pigeon Forge. That same day, FEMA approved an FMAG for Tennessee to support fire suppression activities.

On December 15, following a request by the governor of Tennessee on December 9, the President issued a major disaster declaration for Sevier County. On December 23 and December 28, FEMA—in collaboration with the state and counties—opened Disaster Recovery Centers in Gatlinburg and Pigeon Forge, respectively.

The Tennessee wildfires ultimately burned approximately 17,000 acres, destroyed 2,545 structures, and led to 14 fatalities. See figure 8 for a map of the fires’ location, tables 6 and 7 for data on FEMA’s mission assignments, Individual Assistance, and Public Assistance support.

Northern and Southern California Wildfires, October 2017

On October 8, 2017, multiple fires began burning in northern California, spreading rapidly due to high winds and dry conditions. Among these fires was the Tubbs Fire in Sonoma and Napa Counties, which was, at the time, the most destructive fire in California’s history. On October 9, 2017, FEMA approved FMAGs for ten separate fires.

On October 10, 2017, the President issued a major disaster declaration at the request of the state for seven counties—Butte, Lake, Mendocino, Napa, Nevada, Sonoma, and Yuba. On October 13, 2017, Solano County and Orange County (in southern California) were added to the declaration. In total, the fires included in this disaster declaration burned 240,138 acres, destroyed 8,924 structures, and resulted in 44 deaths.

From October 17 through November 28, FEMA—in in collaboration with the state and counties—established five Disaster Recovery Centers to assist disaster survivors. See figure 9 for a map of the fires’ locations, and tables 8 and 9 for data on FEMA’s mission assignments (including FEMA’s assignment of debris removal responsibilities to the U.S. Army Corps of Engineers), Individual Assistance, and Public Assistance support. Figure 10 provides an aerial snapshot of the destruction in one area of the city of Santa Rosa in Sonoma County.

Southern California Wildfires, Flooding, Mudflows and Debris Flows, December 2017

On December 4, 2017, the Thomas Fire started burning in Ventura County. Over the next three days, the Thomas Fire and other wildfires spread rapidly through Ventura and neighboring counties—due in part to the Santa Ana Winds—and FEMA approved a number of FMAGs for these wildfires.

On December 20, the governor of California requested a major disaster declaration for Los Angeles, San Diego, Santa Barbara, and Ventura Counties. The request was approved on January 2, 2018 for Santa Barbara and Ventura Counties for Public Assistance. In the week that followed, heavy rains exacerbated the damages caused by the fires, leading to mudflows and debris flows. On January 10, FEMA expanded the disaster declaration to include the flooding, mudflows, and debris flows related to the wildfires. Five days later, FEMA added Los Angeles and San Diego Counties to the disaster declaration, and granted all four counties eligibility for Individual Assistance, in addition to the Public Assistance eligibility previously approved.

From January 19 through February 5, 2018, FEMA—in collaboration with the state and counties—established five Disaster Recovery Centers to assist disaster survivors. The Southern California wildfires, debris flows, and mudflows ultimately burned 308,083 acres, destroyed 1,378 structures, and caused 23 fatalities. See figure 11 for a map of the fires’ locations, and tables 10 and 11 for data on FEMA’s mission assignments, Individual Assistance, and Public Assistance support.

Northern California Wildfires and High Winds, July 2018

On July 23, 2018, the Carr Fire began burning in Shasta County. On July 27, 2018, the Mendocino Complex Fire, a combination of the River and Ranch Fires, began burning in Lake County. FEMA soon approved FMAGs for these fires. On August 4, 2018, the President issued a major disaster declaration for Shasta County, which was ultimately expanded to include Lake County. On August 9, 2018, FEMA—in collaboration with the state and counties—established a Disaster Recovery Center in Shasta County, with a second Disaster Recovery Center established in Lake County on August 21, 2018.

One of the wildfires—the Mendocino Complex Fire—was the largest fire in California’s history, burning 459,123 acres. In total, the Carr and Mendocino Complex Fires burned 688,774 acres, destroyed 1,894 structures, and resulted in 4 deaths. See figure 12 for a map of the fires’ locations, and tables 12 and 13 for data on FEMA’s mission assignments, Individual Assistance, and Public Assistance support. Figure 13 shows the aftermath of the Carr Fire in one residential neighborhood.

Northern and Southern California Wildfires, November 2018

Information on Fires and Assistance Provided

On November 8, 2018, the Camp Fire struck the city of Paradise in Butte County. According to California’s Department of Forestry and Fire Protection, the Camp Fire grew into the deadliest and most destructive fire in California history, resulting in 18,793 structures destroyed, 153,336 acres burned, and 85 deaths. On the same day two other major fires—the Woolsey Fire in Los Angeles County and the Hill Fire in Ventura County— began.

On November 8-9, FEMA approved FMAGs for these fires, and the President issued a major disaster declaration for these counties on November 12, 2018. FEMA—in collaboration with the state and counties—opened a Disaster Recovery Center in Butte County on November 16 and four other Disaster Recovery Centers in Butte, Ventura, and Los Angeles counties over the next month. In total, the three fires resulted in 20,295 structures destroyed, 254,816 acres burned, and 88 deaths. See figure 14 for a map of the fires’ locations, and tables 14 and 15 for data on FEMA’s mission assignments, Individual Assistance, and Public Assistance support.

Appendix III: Comments from the Department of Homeland Security

Appendix IV: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact above, the following staff members made significant contributions to this report: Kathryn Godfrey (Assistant Director), Adam Couvillion (Analyst-in- Charge), Elizabeth Dretsch, Ricki Gaber, Eric Hauswirth, Hannah Hubbard, Tracey King, John Mingus, Ben Nelson, and Kevin Reeves.