Comment Submitted by Bruce Glasscock

City of Plano, Texas Response Public Assistance Eligibility Docket ID FEMA -2006-0028 Opposed to the changes for the following reasons: 1. Federalism: State and local governments may be able to handle localized, minor disaster type situations, but for a disaster with the magnitude of destruction of a Katrina, that encompassed many communities across several states, it would not be practical for local governments to administer individual aid agreements. The success of mutual aid agreements relies on the fact that they are planned and negotiated in advance of a disaster. It would be extremely inefficient and prohibitively voluminous for local entities to pre-determine which cities across the United States it should enter into agreements with for assistance purposes. Furthermore, interstate agreements would be difficult to enforce. The Federal government has the resources and is better equipped to manage and control a disaster on the scale of a Katrina. The administrative flexibility of dispensing of the requirement of a Presidential directive does not outweigh the burden placed upon local governments in assisting in evacuating and sheltering disaster victims. 2. Economics : This proposal is not economically practical for local governments. Using Katrina as an example, the City of New Orleans resources were seriously and significantly debilitated as a result of the disaster. Relying on information from the City of New Orleans 2006 Budget Report, they are projecting their total tax revenue to be down 80% - which would include primarily sales tax and property tax. Also, the report contains an "Other Financing Sources" category. This category is projected to increase from $21 million to $217 million - a 939% increase. This is most likely a result of FEMA/Federal funding. The huge increase in this category is still not enough to offset all other lost revenues. Based on this information, it would be economically prohibitive for cities to provide disaster evacuation assistance when they cannot rely on the disaster area to have the necessary funds to pay the assisting local entities. Additionally, it is most likely that payment to participating local governments would not be a priority for the disaster area in a time of crisis on the scale of a Katrina. The FEMA proposal states that the eligible applicant will reimburse the providing entity and THEN be reimbursed by FEMA. Bureaucratically and logistically, this does not sound like an efficient or practical solution for cities. This plan would not create a safeguard for taxpayer monies and would most likely result in cities not participating in providing assistance. Summary : While the administrative burden at a Federal level may be reduced, the proposed plan would place a disproportionate burden on local governments. It may work better at a state level but would work best at a Federal level when considering a disaster the magnitude of Katrina. The change would most likely discourage local entities from risking participating in the assistance of evacuees for shelter purposes. The City of Plano opposes the change due to the foregoing reasons. Comment on FR Doc # E6-11128