I like this report because it fills two major information gaps:
Legislative Analysis: The new CRS report ( 31 pp.) is available here: CRS on Sandy
HUD’s Role Post Disaster: If you share my interest in HUD’s new role in response and recovery, the CRS document provides some helpful background information.
For some details on HUD’s performance after H. Katrina, and some recommendations for its greater involvement in disaster response and recovery, see this 2009 Senate report: Far From Home: Deficiencies in Federal Housing Assistance After Hurricane Katrina and Rita and Recommendations for Improvement. Special report of the Senate Ad Hoc Subcommitee on Disaster Recovery;Feb. 2009 (290 pages).
Recovery Diva 
Comment from William Cumming:
I worked in FEMA from 1979-1999! I essentially wrote off any personal effort in the recovery process for several reasons. First, I was never assigned official responsiblity to do so. Second, more than enough problems existed within the FEMA stove pipes including National Security, preparedness, mitigation, response and and matters related to them.
But I actually worked on EM issues and policy while on Active Duty from September 10, 1967 to July 10,1970 and on return to IRS during Tropical Storm Agnes and the Wage, Price, Rent freeze. And of course was one of the principal lawyers for FIA and FDAA from July 1, 1974 until April 1, 1979.
Knowing how much HUD leadership hated disasters was one issue I was concerned with from the point of view of lawyering two administratively fragile programs, flood insurance and disaster relief. Why would HUD be so up set at these two relatively small federal efforts.
The principal reason I discovered for the HUD leadership anger was the fear of exposure that most of the HUD urban development and community development effort went to investment in the nation’s flood plains. Perhaps up to 65% or more. This is my estimate and I called for its official study in HUD’s policy development and research arm but that was rejected. That organization was devoted to a largely meaningless economic analysis of housing in the USA that no person or organization regarded highly.
Thus, even today but especially in the past HUD Model Cities funding, Community Block Grant funding, and other Urban Development money goes where the politicians and HUD officials want it. Highly vulnerable hazardous areas. And always remember MOTHER NATURE DOES NOT GRANT VARIANCES!
The CRS document highlights a number of critical policy measures for improving the recovery process in the aftermath of Hurricane Sandy. Perhaps the most important of these, at least in my opinion, center on streamlining the Individual Assistance/Hazard Mitigation processes; improving the stock of post-event rental housing for disaster survivors; and administering specific grants based on estimated, rather than actual costs. Nonetheless, the document fails to address the underlying rationale for establishing HUD as the lead agency for the recovery effort, thus raising a number of serious questions. Does the move indicate that the root problem resides in the competency of FEMA itself? Does it indicate that the problem is inherent in the organization structure of traditional recovery? Does the move reflect symbolic or simple political maneuvering in wake of a significant, focusing event? Or perhaps, does it simply reflect the persistent failure to fully comprehend the complexities associated with the recovery environment?
In considering these questions, it is hard for me to identify any supporting evidence for the first two questions. Indeed, the failure of recovery systems can hardly be attached to any single entity or organization, nor can it be easily attributed to the overriding or extant recovery systems structure. Rather, the notion of recovery failure is often a byproduct of lacking pre-event capacity, along with an over-accumulation of negative, recovery-generated demands (e.g. conflicting sociopolitical pressures) that ultimately tear down the system from the inside out. Such negative demands emanate both within and across all system actors, and through all levels of government, thus they cannot be rectified or effectively managed by the mere institution of “new” leadership, particularly under an agency (i.e. HUD) that has limited vision (and understanding) of the broader disaster recovery spectrum. Without doubt, the system is plagued by overlapping functions and fragmentation, but it is also hampered by simplistic thinking, lacking motivation, inadequate planning, and poor learning and/or knowledge integration among all organizational actors, both public and non-public. In this sense, the solution is far removed from the narrow (and potentially confounding) aspects of organizational restructuring. I fully concur with Weber’s comments that, “FEMA has extensive experience playing the part of a federal coordinating agency, one with existing relationships and institutional experience in managing the challenges that are likely to arise throughout the Sandy response effort. That experience should be embraced, even in the light of previous difficulties.”
Such consideration leads to me to the significance of the last two questions, with a specific focus on the “persistent failure to fully comprehend” the recovery environment. The history of emergency management certainly supports this conclusion, as responsible organizations/leaders have consistently sought the equilibrium and stability required for rational problem management. However, two obstacles have incessantly hindered this pursuit: problem complexity and adversarial politics. In recent years, the literature has brought problem complexity to the fore, with many scholars focusing on the persistent occurrence of “satisficing” behavior or the institution of simplified and/or convenient measures to address complex phenomena. This approach, in some cases, has led to partial solutions at best, while, in other cases, it has prompted unintended consequences, to include the further exacerbation of existing problem impacts. The issue centers on the fact that policy decisions are generally misguided – they either fail to properly address the causal mechanisms underlying the problem or they are simply based on faulty logic or analysis. This reality is further complicated by the conflicting nature of the overriding policy process. The political arena is defined by adversity and struggle, rather than the collaborative spirit, which naturally heightens the incidence of competition, conflict, and zero-sum games. The punctuated equilibrium theory, for instance, posits that a given policy solution is met by myriad of adversarial positions that essentially linger until confidence in the standing policy erodes under its feet. In turn, the problem definition stream is essentially reopened, and oppositional forces aggressively maneuver to supplant the standing policy with their own policy preferences.
The efficacy of these policy preferences is rarely known however, yet acceptance is blindly granted in the wake of “blame” seeking and arguments for necessary change. Perhaps the designation of HUD as the lead agency for the Hurricane Sandy recovery effort is no different… another political move to codify a sense of change, but with little understanding of how it will actually impact the recovery effort. If so, the decision may result in a familiar pattern of systemic failure, one that has consistently emerged in the aftermath of recent disasters and catastrophic events (e.g. Hurricane Katrina). Indeed, until all of these fundamental problems can be addressed by the relevant stakeholders within the various systems of emergency management, the use of such restructuring tactics stands as not only futile, but also a waste of critical energy and resources.
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Scott Manning is a Doctoral Student/Instructor at the Department of Emergency Management, Jacksonville State University
Hi Scott: It would be helpful if you could provide your organizational affiliation so that readers know your background. You seem to speak from extensive experience.
Thanks for your comments. I am busy pondering them.
FEMA’s role has always been one of a coordinating federal entity; never has it been defined as a management organization in charge of the incident response. This is just one reason that the use of HUD as filling the lead role is so baffling. FEMA has extensive experience playing the part of a federal coordinating agency, one with existing relationships and institutional experience in managing the challenges that are likely to arise throughout the Sandy response effort. That experience should be embraced, even in the light of previous difficulties. The complications that arose in previous response and recovery efforts can be traced to a long list of factors, both within and without FEMA. These challenges are not likely to be overcome by placing a new organization, lacking the critical experience and structure of traditional emergency management organizations, into that role.
This is not to say that HUD does not have a responsibility to play in supporting the Sandy recovery effort. Their experience in housing and urban development would be invaluable in supporting the housing recovery effort. To that end, it would be wise to have FEMA mission assign HUD to make available their knowledge, expertise, and personnel to support the mission. However, it is important to note that this capability already existed prior to Superstorm Sandy, and it could have easily been implemented without congress drastically changing major federal systems with a wave of their hand.
Lessons are not learned in the heat of battle; we must have the foresight to review out shortfalls after that fact and seek to overcome them while we have time to improve our capabilities and processes. The placement of HUD in their current role is shortsighted and is reflective of a longstanding federal tradition of throwing money at a problem without first establishing that the money, or the core theory it is meant to support, is the right choice to make. If HUD is to play a bigger role in emergency response and recovery allow them to develop those capabilities before the fight begins. Once they have the systems, manpower, capabilities, and principles in place to meet the mission requirements, then send them in. Until that point is reached, we need to step back and allow ourselves to be less concerned with making changes for changes sake and more concerned with doing it right.
You make some excellent points. I agree with you. Plus, HUD does not appear to be ready to take on the new challenges .
I, too, was surprised to learn that HUD was given the lead on Hurricane Sandy response and recovery. I, too, saw that FEMA’s performance post-Katrina left a lot to be desired. But I see no way that an Emergency Management agency and a Housing agency are interchangeable. It makes total sense for HUD to be given the lead on housing issues post-disaster. Having HUD perform that function under FEMA during a disaster response and recovery should have each agency doing what they do best. Forcing HUD to learn to manage a disaster response, while performing a disaster response, seems to be asking for the impossible. If FEMA leaders aren’t running the agency properly, find leaders who can. Don’t toss out the agency.
Giving HUD the lead is even more interesting after reading the section in the Far From Home report from the Senate Ad Hoc Committee stating that HUD was unable “to provide sufficient housing for its own beneficiaries” and questioning how well it would perform this function on a much larger scale (p. 23). With this question unanswered, HUD was given charge of the entire project?
Due to the cost of the “mega” disasters recently as well as the increase in populations that seem to be affected, the main benefit from the Sandy Recovery Improvement Act of 2013 is the amendment to direct FEMA to create a comprehensive national strategy for reducing the cost of future disaster (Section 1111). Hopefully, this will be driven and supported by all divisions and levels of government. This is key to help keep costs at a “manageable” level in the future as well as help mitigate against disasters to hopefully save lives and property.
I was surprised to find that HUD was leading the recovery efforts following Hurricane Sandy. On one side, I feel that the agency with the most experience in recovery should be leading the recovery efforts. Although there have been some major issues with FEMA, the lessons learned will hopefully help them when facing adversity in the future. One of FEMA’s purposes, along with their experiences, is to lead the recovery process. So, why would you not use the agency with the experience and skills?
On the other hand, there have been numerous times where FEMA has fallen short in their efforts. One must ask how many times can one mess up and nothing change? The interesting point is that the time-frame following a disaster is a crucial times and the not a time for an agency to be irresponsible. The is a good learning experience for all governmental agencies. It will be interesting to see how it turns out and who will be chosen to lead following the next disaster.
Just some thoughts….
Following the demise of Project Impact, I think that the renewed focus on reducing the costs of future disasters via Section 1111 of the Sandy Recovery Act is both a necessary and healthy step for the practice of emergency management. This is a necessary step because the cost of disaster is constantly increasing, either through the increasing value of our property or through the increasing intensity of the disasters that we are experiencing. The long term impact of the costs of disaster will surely significantly impact the financial strength of our communities and, quite possibly, our nation.
Additionally, I think moving towards a greater emphasis on mitigation is a healthy step for the practice of emergency management. In many ways, it is very similar to the resistance that some fire departments have with the practice of mitigation in their profession. Sprinkler systems and fire code enforcement isn’t as exciting as responding to a fire, but both are proven approaches that save lives. Structural and non-structural mitigation projects aren’t nearly as dramatic as responding to a disaster, but the personal and financial impact on the lives of those we serve are greatly impacted by how well we mitigate disaster, more so than how effectively we respond to disaster.
I applaud FEMA’s efforts to establish a National Mitigation Framework that can serve as a national strategy and template for America’s states, counties, and municipalities to reduce the impact of the disasters of the future. That said, I would encourage FEMA to push beyond the framework alone and pursue a comprehensive strategy that addresses comprehensive emergency management, incorporating the independent mitigation, preparedness, response and recovery frameworks into one coordinated strategy and framework, drawing all four frameworks into one national strategy.
I find the vertical silos inherit in the federal bureaucracy to be a bit maddening. We have so many agencies, divisions, and departments, with overlapping goals and objectives. While there may be enough mission specialty, in general, to rationalize their existence, I often question the efficiency and efficacy of the overlap and redundancies. This questioning is along the lines of budget and operation. While much of the banter today centers along budgetary lines, the general operation is also of great importance. The government is often too large to get out of its own way to effectively accomplish a mission.
My first thought regarding HUD involvement in disaster recovery was, “Why?” It conjured thoughts of every law enforcement arm of the federal government being involved in drug investigations. While the Drug Enforcement Administration was established under the Nixon administration to provide “a single unified command” to combat drugs, this never became a reality to my thinking. The FBI, ATF, ICE, and many others all have drug enforcement arms. Worse yet, they often compete and get in the way of other agencies. This is largely due to territorialism and lack of information sharing. The drug enforcement issue is not unique within the federal government. Apparently we experience the same issues when applied to emergency response or disaster recovery.
There must be a lead or coordinating agency with some structure. Other agencies of the government should be placed into the response and recovery recipe with a keen eye toward specialization. My initial opinion is that FEMA should take the leadership role for the response and recovery; that is, after all a major component of their mission. Other agencies within the federal government may fit in a response/recovery package based on expertise. If housing is an issue, HUD should become part of the effort (their component reporting to FEMA for the operation). If infrastructure security is an issue, we should look to military or law enforcement for this component; again I stress this should be a component of the overall operation with FEMA having operational control. Each agency trying to maintain control over its fiefdom as it is a part of a larger response operation is arrogant and begets plummeting efficacy and efficiency. If all of the agencies could roll up their sleeves and agree to cooperate without worry over who gets credit, who is in charge, or whose budget is affected, we might do some good for a victimized population.
Just my editorial take…