Comment Submitted by Alan J. Prenger, Missouri State Emergency Management Agency

State: MISSOURI Total number of federally declared disasters that occurred: FY 2006: THREE (3) FY 2007: FIVE (5) FY 2008 (After 11 November 2008): TO DATE : SIX (6) and ONE (1) EM We are currently conducting damage assessments for another potential declaration. For disasters in FY 2006 and FY2007, the percentage costs for our state to administer and manage the Public Assistance Program were: FY 2006: Average Cost was 7.6% FY2007: Average Cost was 8.8% FY 2008: Estimated cost is 10 % DR # STATE ADMIN GRANTEE ADMIN SUB - GRANTEE ADMIN PEND CAT Z OTHER STATE MGNT NOT CLAIMED TO FEMA TOTAL GRANT TOTAL PW GRANT % FFY '06 1631 263,195.96 76,633.07 145,338.58 485,167.61 5,541,710.24 8.7548% 1635 324,466.68 153,500.72 291,122.05 7,555.04 776,644.49 10,880,440.17 7.1380% 3267 370,680.23 154,881.58 293,740.94 819,302.75 11,028,992.49 7.4286% FFY '07 1667 33,106.28 9,236.46 17,517.43 59,860.17 670,103.70 8.9330% 1673 294,738.13 90,804.34 172,215.14 557,757.61 6,566,855.85 8.4935% 1676 4,611,789.36 1,572,401.94 2,982,141.64 9,166,332.94 111,018,400.93 8.2566% 1708 381,792.44 111,227.76 210,949.23 144,404.95 848,374.38 8,041,803.15 10.5496% 1728 237,965.87 80,147.51 152,003.92 470,117.30 5,736,031.09 8.1959% The series of new disasters issued for the State of Missouri since the effective date of the Interim Rule have generated additional expenses above and beyond those required to process and manage the Public Assistance Program for these and the remaining open disasters declared prior to the implementation of the Interim Rule. The State has had to hire additional temporary staff to augment the current staff of five personnel. Additionally, State expenses have increased due to the increased support provided to local jurisdictions for Emergency Protective Measures (Category B). The repetitive need to conduct multiple Joint Damage Assessments and multiple Applicant Briefings have delayed processing at the JFO, as well as, postponement of site visits and closeout procedures for the current and previous disasters. The implementation of this Interim Rule has forced the State into a position of not being able to provide any Grant Management funding to the subgrantees except that which they can document as specifically and directly associated with a specific Project Worksheet. This additional administrative burden is beyond the capabilities of most applicants. Therefore, participation in the Public Assistance Program becomes even more costly to the applicants. The refusal of FEMA, Headquarters to enter into a dialog with the States and Regions concerning their questions regarding the implementation of this Rule has, at best, resulted in confusion and wasted effort on the part of States to develop administrative plans and other operating guidance for their programs and applicants, only to be told ‘you cannot do it that way’. It has also caused degradation of the “Partnership” relationship FEMA espouses to have with States. The assertions by FEMA, Headquarters that “grantees and subgrantees are reasonably expected to contribute at least a comparable amount of management cost funds” and that the “sharing of costs leads to better fiscal responsibility and accountability” reflect a serious lack of understanding of the program. The Public Assistance Program has been a cost - share since inception. The States and local jurisdictions have always had to bear a portion of the costs of disasters. This sharing includes the Management costs. The previous “sliding scale” did not completely cover the management costs of disaster. The States and local jurisdictions have always “shared” that burden. The “sharing” this Interim Rule imposes is to increase the State and Local “share” of the costs of a disaster. The premise of a disaster declaration is that the event(s) are beyond the capabilities of the State and local jurisdictions to handle. Reducing the Federal assistance, as this Interim Rule does, merely shifts more of that extraordinary burden back to the disaster victims. Re: Question 8 in the NEMA “State Management Costs Quick Survey.” “For disasters in FY 2006 and FY 2007, what were the percentage costs for your state to administer and manage your state’s Hazard Mitigation Grant Program.” It is difficult to provide a simple percentage answer to this question due to the changes in allowances imposed by FEMA over the years and the way Missouri’s Mitigation Program staff of 3 people have had to use the administrative and management funding. For example, in the 4 years from 1998 to 2002, Missouri managed about $15.5M in HMGP and Unmet Needs funding. However, our workloads were more manageable during these years and FEMA used a more liberal interpretation of how the states could use administrative funding. Missouri received a federal lock-in of $7,562,379 for MO-DR-1403 declared February 6, 2002. We requested management funding of $33,750 and spent $29,911 to contract Closeout Reports. We also requested $62,647 to perform local Hazard Mitigation Plan reviews. However, the Regional Planning Commission that performed our reviews charged much less than we anticipated and we performed some reviews in-house, so we only spent $8,468 on the reviews. In this case, we ended up spending a little over one half a percent on the management costs. Our percentage costs for our other disaster during this timeframe was slightly less with a federal lock-in of $5,902,891 and management expenditures of $27,401 due to simpler and lower cost Closeout Reports. During the next 4 years from 2002 to 2006, we managed another $15.6M in HMGP funding as well. When FEMA imposed increasing restrictions on the use of administrative and management costs and Pre-Disaster Mitigation (PDM) funding began to spike for Missouri during the awards made in 2006, things became more difficult to manage and we requested and expended PDM management funding to help cover the Closeout Report and planning review workload. In FY 2006, MO-DR-1631 resulted in a federal lock-in of $1,290,726. We did not request management funding for that disaster. MO-DR-1635 brought in another $4,210,525, and we requested $45,000 in management funding for those Closeout Reports because we had begun to manage a sizeable PDM project load as well. In FY 2007, MO-DR-1667, MO-DR-1673, MO-DR-1676, MO-DR-1708 and MO-DR- 1728 resulted in federal lock-ins totaling about $24M, and we requested $101,250 management funding for preparing Closeout Reports and performing planning reviews for local Hazard Mitigation Plans that are reaching their 5-year updates. We were authorized in our state general revenue budget to contract Planner II services to help manage the updates, so that boosted our Mitigation Program staff to the equivalent of 4 people. In FY 2008, MO-DR-1736, MO-DR-1742, MO-DR-1748 and MO-DR-1749 have resulted in federal lock-ins totaling about another $18.4M, and we do not yet have the federal lock-ins for MO-DR-1760 and MO-DR-1773. We anticipate requesting additional management funding for the projects and plan updates we will fund under these disasters, but do not yet know the amount we will seek. We also are seeking in our state general revenue FY 2010 budget to add permanently two additional Planner II full-time personnel to our Mitigation Program staff. Bottom line is that administrative and management funding has been so restricted by FEMA restrictions, the need for additional personnel authorizations and/or contract establishment, planning workloads, peaks and valleys in the numbers of disasters, the scope of the disasters, workload balance, PDM success and availability of funding that it is very difficult to determine what is needed. Thanks for asking!!