IAEM-USA Submits Comments on FEMA Disaster Deductible Proposal

IAEM-USA, on Apr. 12, submitted comments on a FEMA’s concept of a Public Assistance deductible that would condition states’ receipt of FEMA reimbursement for the repair and replacement of public infrastructure damaged by a disaster event. The primary intent of the deductible concept, according to FEMA, is to incentivize greater state resilience to future disasters, thereby reducing future disaster costs nationally. On Jan. 20, 2016, FEMA published an Advance Notice of Proposed Rulemaking (ANPRM) seeking comments on a Public Assistance deductible concept. The ANPRM provided a general description of the concept that many commenters found insufficient to provide meaningful comment. In an effort to offer the public a more detailed deductible concept upon which to provide additional feedback, FEMA is issuing a supplemental ANPRM (SANPRM) that presents a conceptual deductible program, including a methodology for calculating deductible amounts based on a combination of each state’s fiscal capacity and disaster risk, a proposed credit structure to reward states for undertaking resilience-building activities, and a description of how FEMA could consider implementing the program. After considering feedback, FEMA may expand on or redevelop this concept.

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