Wednesday, February 9, 2011

Does FEMA need to be a leader in MITIGATION?

The concept that non-structural approaches could significantly reduce flood losses (meaning average annual flood losses) was a concept underlying Gilbert White's 1943 PhD thesis at the University of Chicago in the discipline known then and now as GEORGRAPHY! Human adjustments to flooding are in fact still the key fact of life for FEMA and its mitigation efforts. Yesterday in the Federal Register FEMA noticed a potential change in Levee Policy for the disaster programs, functions, and activities and made no repeat NO reference to the impacts of that policy on annual average flood losses or its own NFIP.

Mitigation started in the independent FEMA as a PAS level V, the lowest level with a Mitigation & Research Directorate. Then mitigation was combined into the FEDERAL INSURANCE ADMINISTRATION in September 1981. It did not reappear as a separate Directorate until November 1993. That ended in a reorganization occurring in 2001.

At one time the mitigation effort had elements in which by statute FEMA was the lead federal agency. First the Earthquake Hazards Reduction Program and also the DAM SAFETY program. It would be interesting to know how the loss of leadership in these two programs has impacted the leadership generally of FEMA as one of the foremost mitigation agencies. It is certain that few of those leading FEMA's disaster programs have ever read a copy of the NFIP insurance policy or are aware of FEMA's formative efforts to combat the structural agencies in even getting a dam safety program in place.
There is a pre-disaster mitigation strategy published in 1997 posted on this blog on the homepage under FEMA Historical Material and also a NATIONAL MITIGATION STRATEGY. Recently FEMA apparently in ignorance of both these documents existence has announced again that it would work on a National Mitigation Strategy. Well the way it is going one primary goal should be to produce a history of the mitigation component in FEMA, how FEMA often undermined mitigation through its programs, functions, activities and various policy decisions and how little DHS understands or supports FEMA mitigation activity.

Well a big earthquake, a large dam failure, a large flood event could all result in a witch (which?) hunt that will involve FEMA. Personally I think all those who have led the FEMA mitigation effort, if alive, should be assembled for a week long conference identifying past efforts and establishing a basis for new policies. Faced with NFIP reform this year in the Congress it will be interesting to see what and how FEMA suggests statutory changes. Note that two MISSISSIPPI US Senators have suggested in published remarks that FEMA should credit all levees on its maps even if proposed for construction well down the road, meaning a decade or two off.

All MITIGATION staff in FEMA should be trained on the existing 1983 Principles and Standards for Water Resource Projects, and the NAS study of proposed revisions and the outstanding revisions suggested by CEQ at the WH. They should all also be given a copy of the NFIP flood insurance policy and also given background information on STATES efforts to conduct successful mitigation. Perhaps the ICC (Increased Costs of Construction) effort of the NFIP and its successes and failure should also be discussed.

And one of the two Deputy Administrator positions in FEMA should be for MITIGATION, or perhaps just add a third.

After all the real job of the FEMA Adminsitrator is not to promote disaster programs but to reduce disaster outlays. This year that concept will drive a difficult year in Congress for FEMA and its leadership.