The well-documented increasing toll of disasters in terms of life
and property losses should trigger major reform of the nations
hazard mitigation policy and programs. A potential strategy for
reform would emphasize changing the incentives faced by local
communities (municipal-level of government) and also would mean
moving from a voluntary program with one-size-fits-all rules to a
mandatory program with adaptive rules that facilitate
implementation under a variety of different local conditions.
The current mitigation framework is based on voluntary
participation. However, mitigation research shows that the
potential benefits do not drive actual development decisions and
that voluntary programs fail to trigger action that reduces risk. A
voluntary mitigation framework cannot be expected to yield
significant results andgiven the increasing cost of disasters and
catastrophesthe voluntary approach has become outdated. Mitigation
should no longer be an option, and the rules governing mitigation
programs must be adaptable to local conditions.
The New Orleans Experience
New Orleans experience in implementing mitigation programs
following Hurricane Katrina offers a window into the conundrums
that a community faces when struck by a catastrophe. It also
illustrates the range of local tactical knowledge generated to deal
with those conundrums, as well as the value this knowledge can
bring to policy reform and adaptive program implementation.
Mitigation program implementation in New Orleans was compounded by
the fact that few if any funding resourcesboth governmental and
philanthropicwere willing to give money directly to citizens or
local governments in Louisiana because of its earned reputation for
corruption and fund mismanagement. Consequently, local officials
were driven to create convoluted processes to prevent direct
transfers of money to citizens and local government, without
admitting as such. To be sure, local practitioners face tremendous
obstacles erected to alleviate bureaucratic risk.
Figure 1 offers a stylized map of significant mitigation issues
officials faced during the five-year period following Hurricane
Katrina. It attempts to simplify a complex reality for the purpose
of highlighting local implementation experiences associated with
one of the most significant urban disasters in U.S. history. Many
of these program insights were only discernible from the
perspective of the local practitioner, who felt the issues
directly. Other issues, especially the cumulative ones, have been
widely acknowledged because they were visible from a broader
perspective, such as by state and federal officials.
Pre-Disaster Issues
Unfortunately, finding rational ways to manage the distribution and
prioritization of funds for such a large urban area with thousands
of structures on the repetitive loss list proved nearly impossibl
especially with most of the homes being eligible for funding.
Eligibility Criteria
In New Orleans, hazard mitigation program eligibility criteria
established by the state resulted in prioritizing funds to areas of
the city that had already been mitigated by other means while
neglecting areas of the city at highest actual risk. When these
inequities were pointed out to state and federal officials, there
was no response by those in a position to make changes. A local
solution would be to design a policy for distributing mitigation
funds on the basis of risk.
Risk Information
There were categories of risk not covered by the existing lists of
at-risk properties maintained by the Federal Emergency Management
Agency (FEMA): repetitive loss (RL) and severe repetitive loss
(SRL) property lists. RL and SRL lists cover high-frequency risk,
but many areas of New Orleans wereand still aresubject to
high-consequence risk and blight risk.
Another problem is that FEMA flood maps tend to gloss over risk
outside the 100-year floodplain and are silent on the notion of
residual risk. Mitigation programs that rely on these two main
sources of risk information tend to focus on individual properties
that are either listed or zoned. This limited approach encourages
local communities to ignore non-listed or non-zoned properties
still at risk. A local solution would be to make program
implementation flexible enough to handle areas where FEMAs lists
and maps do not adequately represent or cover the actual range of
risk.
Period 1 Issues
Potential issues for the period immediately following a disaster
include conducting initial damage estimates, providing start-up
costs, and developing safe design elevations for rebuilding
efforts.
Damage Estimates
Conducting reasonable damage estimates and enforcing widespread
mandatory elevations after a city suffers a catastrophe was
infeasible in New Orleans due to the sheer number of damaged homes.
This problem remains completely unaddressed and may occur again if
officials do not reform the program. Local jurisdictions should not
be expected to prevent their residentsin this case nearly 300,000
peoplefrom returning to their homes en masse, as was expected after
Hurricane Katrina. In this situation, the rules must be adaptable
to local reality. A local solution would be to pre-apply for
emergency mitigation funds that would cover the costs of
post-disaster damage estimates.
Start-Up Costs
Beyond the cost of delays, the mitigation program proved
structurally unsound because it only provided funds to entities
that already had access to start-up capital. Lack of start-up
capital meant that even after the local jurisdiction received a
mitigation award letter, it needed to have its own resources to
begin work. Start-up funds were needed not only for construction,
but for project management, planning, architectural design, and
engineering.
A local solution would be to establish sources of start-up money
prior to the next disaster, such as by negotiating with the state
to allow the use of future state construction funds as start-up
capital for low-income properties only and to require homeowners
not considered low income to provide their own start-up capital.
Safe Design Elevations
It was difficult to determine the safe design elevation in New
Orleans because many areas were subject to multiple, simultaneously
changing conditions, including the levees and drainage systems that
were under construction, as well as areas with wildly varying
damage estimates. FEMA issued advisory base-flood elevations to New
Orleans in 2006 and preliminary digital flood insurance rate maps
in 2008.
Both of these attempts to provide safe design elevations were based
on interim decisions and temporary conditions. Consequently, the
information did not promote confidence. A local solution would be
to produce constantly updated, independent information about local
risks and safe design elevations and to enforce the minimum safe
design elevation consistently.
Period 2 Issues
Unnecessary layers of review of mitigation applications at both the
state and federal level resulted in years of delay in getting funds
to the New Orleans community. In addition, frequent changes to
program rules and proceduresoften received third-hand or by
word-ofmouthmade the mitigation program a moving target.
Reviews
Mitigation applications were routinely audited and inspected at
unreasonable levels, and there was little that local officials
could do to circumvent this tactic. Delays caused increases in
construction cost estimates that exceeded by orders of magnitude
the small change counted from rounding errors. A local solution
would be to assemble pre-approved application templates, databases,
and procedures to streamline and formalize those aspects of the
application process that are within the communitys control. Also,
using a third party to manage aspects of the application process
that are outside the communitys control could benefit the process.
Procedures
Frequent changes to mitigation program procedures resulted in loss
of momentum at the local level and the need to regroup and adapt to
new rules and procedures. Also, requirements to evaluate the impact
of changes on the existing program were necessary. Finally,
procedural alterations made it difficult to explain the program to
residents or hold state and federal agencies accountable, which
ultimately created unconscionable delays that affected thousands of
people in the community. A local solution would be to ask for the
help of academics seeking to change the Stafford Act.
New Technology and Data
In general, it is difficult and cumbersome to get new technologies
accepted by FEMA as fundable options under the mitigation program.
Local solutions might include collaborating with innovative
architects and city permit officials on demonstration projects and
showcasing these to FEMA mitigation officials.
In other instances, new technology appears to receive little or no
independent review prior to being put into active use in mitigation
programs. A local solution would be to become more involved in
hazard analysis and to encourage third-party certification for
techniques that involve expert judgment and support the legal
enforcement of mitigation and floodplain management program
requirements.
Period 3 Issues
Period 3 following the Katrina disaster focused on issues of
finding availability and determining how competing programs
affected mitigation.
Funding Availability
It routinely takes up to one year after a president declares a
disaster for FEMA to announce how much funding will be available to
repair and mitigate the damage. In the case of New Orleans,
mitigation funds have still not been fully disbursed, and
disbursement procedures are still being changed. A local solution
to gross delays in disaster-based funding would be to develop
shovel-ready projects and pre-disaster applications to reduce
postdisaster wait time.
Competing Programs
The introduction of other competing mitigation programs that were
heavily promoted compounded the lack of direct communication
between FEMA and the community. Additionally, constant delays to
the traditional mitigation program created significant confusion
for homeowners and local officials. These two factors stole scarce
resources from already short-staffed local officials who also had
to compensate for the lack of clearly defined rules. A local
solution would be to determine which mitigation programs make sense
for the city to manage, avoiding duplications and inefficiencies.
Cumulative Issues
Issues with coordination efforts, accountability, and hidden
incentives existed throughout the mitigation process for New
Orleans and surrounding areas. More important, the cumulative
effects of five years of problems have caused financial loss and
unreasonable resource demands on the affected municipality.
Coordination
Lack of direct communication between FEMA and the affected
community contributed to ongoing confusion about mitigation
programs in general, as well as uncertainty about program-specific
requirements, thereby resulting in interminable delays. Even though
the federal program is already spelled out in publicly available
program guidance, the actual rules were redefined by the stateand
many of these rules and procedures were not available to local
officials and the public.
Local jurisdictions did not have direct access to FEMA because
programs were supposed to be implemented at the state-level in
accordance with federal design. This lack of coordination meant
that the mitigation program could not be explained to the public,
and it often appeared to be an incoherent series of independent
decisions disconnected from a stated strategy, policy, or program.
A local solution would be to develop closer relationships with
state mitigation officials to improve communication between city
and state on mitigation programs. Alternatively, in cases where
this is not possible for political reasons, areas could opt out of
state-controlled mitigation programs.
Accountability
There was no direct link between public announcements of funding
allocations and actual expenditure of mitigation funds by the state
or local community, nor was there any accountability for locating
hazard mitigation funds at any given time. Because accountability
mechanisms were not built into the mitigation program, it was very
costly to address these concerns when they arose.
A local solution would be to keep track of funds allocated, funds
received, funds spent, number of structures mitigated, and
beneficial economic impacts for the city and to make the results
available to the public in order to improve accountability.
Incentives
There exist hidden incentives for states to delay distribution of
funds to a municipality, such as
- the financial interest earned on locally allocated funds
- the ability to create and promote programs that deliver a
higher number of small awards over programs that deliver a lower
number of large awards
- the ability to limit local-level discretion in establishing and
meeting mitigation policy objectives.
All three of these tactics were applied in New Orleans. This
approach removed local discretion and reduced the future
availability of mitigation funding to local jurisdictions. A local
solution would be to strengthen and promote those mitigation
activities that are under local control, such as by following
through on the recommendations of the Community Rating System
Program.
Cumulative Effects
Five years of program delays have caused not only financial loss,
but mental anguish for residents. Some New Orleans residents were
displaced for years, and others lost their homeowners insurance due
to the appearance of inaction, which required the municipal
government to step in on their behalf and explain the slow pace of
the federal program to get their insurance reinstated.
Bureaucratic inefficiencies in the mitigation program have resulted
in an excessive waste of staff time, salaries, travel and equipment
expenses, and other resources. The cumulative costs of
participating in a mitigation program are high for most
communities. A local solution would be to seek out and implement
best practices for efficiency and paperwork reduction and to lobby
for mandatory set-asides for local administrative costs.
Program Impacts
The elevation of scattered individual structures may be
theoretically cost-effective, according to the FEMA benefit-cost
analysis software, which force-fits the interest rate and return
period. However, this sort of elevation scheme does not necessarily
maximize the prevention of harm. Likewise, the acquisition of
scattered individual structures may meet FEMA benefit-cost
criteria, but it is often infeasible in an urban setting because of
the local financial cost of maintaining multiple lot-sized green
spaces in perpetuity and the economic cost to the public of
removing urban sites from commerce.
In other words, the actual benefits and costs of mitigation may not
be captured by the standard benefitcost analysis method.
Furthermore, the overall benefits of mitigation are not being
monitored or measured in any significant way that leads to
improvement over time. A local solution would be to
institutionalize mitigation program evaluation and impact
measurement, with results feeding back into program improvements
over time.
Closing Thoughts
The post-Katrina experience is instructive for policymakers and
public officials interested in mitigating against future disasters,
as well as those interested in aspects of the program most in need
of reform. Few cities have had the benefit of as much thought,
attention, and formal planning after a disaster as evidenced by the
long list of formal recovery plans. And few cities have had as much
funding available for hazard mitigation programsmore than $60
million.
Given the wide range of implementation issues faced by New Orleans
mitigation practitionersadded to the difficulties all cities have
in dealing with hazards in generala strategic shift in mitigation
program design is necessary. By unpacking these struggles in a
particular instance, it becomes evident that local implementation
issues have not and cannot be foreseen by high-level policymakers
and that certain localized issues may never achieve the universal
status necessary for high-level resolution. (See Table 1 for a
contrast of local viewpoints with more generalized understandings.)
Bottom line: Mitigation needs to be mandatory, and mitigation
programs should be locally designed. Giving local practitioners
more discretion and influence in designing local program rules that
are relevant to their needs while providing more consistent and
predictable financial support might help resolve the multitude of
problems that currently exist.
