While the outcome of the election for control of the House of Representatives is still to be determined, understandably the attention in Washington has shifted to the 2nd Trump Administration and what might be in-store for different areas of policy over the next 4 years. This past week I spent some quality time with the Heritage Foundation’s Project 2025 Mandate for Leadership: The Conservative Promise, to understand how the conservative movement views the status-quo of federal management of disasters and what reforms it prioritizes. Project 2025 received a lot of attention during the campaign and President-elect Trump was careful to distance himself from the document, but many of the contributors were former (and likely future) administration officials with serious standing within the Republican Party and conservative movement. It is a hefty document - over 900 pages - and undoubtably many of its recommendations will not come to pass. As far as crystal balls go, however, it is one of the clearest views we have of the priorities that members of the next Trump Administration might have. So let’s have a look.
Reforming FEMA
The chapter on the Department of Homeland Security, authored by former Deputy Secretary of Homeland Security (and noted climate change skeptic) Ken Cuccinelli includes numerous recommendations on FEMA:
A top-level recommendation is that DHS be dissolved. However, rather than returning FEMA to its previous status as a cabinet level agency, Project 2025 recommends that it be moved to the Department of the Interior or the Department of Transportation.
An central theme throughout the section on FEMA is reducing the reliance of states on the federal government for disaster response and recovery resources. Central to this goal would be to increase the threshold for major disaster declarations, to effectively reduce the federal role in smaller disaster events. Alternatively it recommends establishing a state disaster deductible, which would achieve the same purpose (and has a bipartisan history with important proponents from the Obama administration).
Another way that Project 2025 envisions shifting financial responsibility for smaller disasters from the federal government to state and local ones is to change the cost-share arrangement for federal disaster programs. Under this arrangement the federal government would pay only 25% of the cost of projects in smaller disasters (down from 75% - 90% under current policy) and up to a maximum of 75% for ‘catastrophic disasters.’
Perhaps the most significant change recommended would be to wind down the National Flood Insurance Program and replace it with private insurance options “starting with the least risky areas currently identified by the program.” This change is meant to discourage risky development in flood zones, thereby increasing the resilience of our building stock.
The plan would also eliminate federal preparedness grants - which it describes as “not provid[ing] measurable gains for preparedness or resiliency” and a source of political pork. “The transition should focus on building resilience and return on investment in line with real threats.”
Lastly, the reform plan in Project 2025 would give a slight amount more power to the Executive Branch over FEMA by requiring Senate Confirmation of only the Administrator, rather than the three top positions in the Agency.
It is worth noting that Project 2205 does not say much about various FEMA programs focused on hazard mitigation and climate resiliency, like the Building Resilient Infrastructure and Communities program or the Flood Mitigation Assistance program. On the one hand the document is focused strongly on building resiliency to disasters and breaking the cycle of federally-funded recoveries. On the other it is also strongly focused on federalism and the responsibility of the states to invest in their resilience.
Other Key Federal Partners in Disaster Management
Beyond FEMA, how does Project 2025 envision the role and functioning of other major federal partners in disaster management? Not surprisingly the blueprint would directly impact many of them.
The Small Business Administration
The Small Business Administration provides low-interest loans to households, businesses and private non-profit organizations post-disaster. Importantly the SBA has its own disaster declaration process and provides assistance in a larger number of events than FEMA. The SBA provides several types of loans post-disaster: to cover repair and replacement of damaged assets, to additionally fund hazard mitigation on those same properties, to cover small business operating losses, and to cover payroll costs associated with military reservists called up to serve.
Project 2025 recommends ending the SBA's disaster loans authority by shifting it to another agency and privatizing the administration of loans. It also recommends that the SBA be barred from developing any further loan programs. No additional details are provided.
Housing and Urban Development
HUD administers the second largest disaster program (Community Development Block Grant Disaster Recovery, or CDBG-DR) and conducts significant research on disasters and housing through its Office of Policy Development and Research and the Healthy Homes Technical Studies Grant Program. The HUD chapter of Project 2025 (authored by former HUD secretary Ben Carson) is mostly ambiguous on the DR program although it encourages Congress to "consider a wholesale overhaul of HUD that contemplates devolving many HUD functions to states and localities with any remaining federal functions consolidated to other federal agencies." The chapter does explicitly address research, saying that the "Office of Policy Development and Research should suspend all external research and evaluation grants..."
United States Department of Agriculture
The USDA is another important source for post-disaster assistance, especially for farmers and ranchers who have experienced losses. Project 2025's USDA chapter does not explicitly address these programs and whether they should be seen as fulfilling the Department’s core mission.
Economic Development Administration
The Economic Development Administration is the lead organization in support of economic recovery under the National Disaster Recovery Framework and works primarily by providing economic development grants in disaster affected areas. Project 2025 recommends abolishing the EDA and 'reallocating its funding to other overlapping federal grant programs.' It does not specify where its disaster grant program funding might be reallocated.
The National Oceanic and Atmospheric Administration
And finally, NOAA. The chapter on the Department of Commerce in Project 2025 really, really doesn't like NOAA, which its author (Thomas F. Gilman, former Assistant Secretary of Administration for DOC) describes as "a colossal operation that has become one of the main drivers of the climate change alarm industry and, as such, is harmful to future U.S. prosperity." NOAA does a tremendous amount of work related to emergency management, from the information provided by the National Weather Service to the CAP/RISA program to supporting partners in pre- and post-disaster preparedness and recovery. Project 20225 recommends disbanding NOAA and significantly cutting its programs, while distributing some of its functions to other agencies or privatizing them (as it recommends for NWS).
Final Thoughts
There will inevitably be a large delta between what Project 2025 envisions and what will happen in the real world, even if the Trump Administration were fully invested in its success (an open question). The Administration’s actions will be very much constrained by politics and the Congress and where they choose to spend their political capital. So ultimately the impact of the next administration on disaster management could range from “not a lot” to “cataclysmic.” The politics of disasters have always been unique and led to strange bedfellows, and actions that seek to shift financial obligations from the federal government to the states will very likely run into opposition from blue and red state representatives alike. There are also some intriguing ideas here about consolidating programs under appropriate agencies and encouraging states to play a larger role in building resilience. I will continue to track and write about these ideas as they bubble to the surface.
Postscript
It is worth acknowledging that I have been less than consistent writing Place + Resilience. Excuses galore, but I plan to do better.