Comment Deadline Tonight on FEMA Disaster Deductible Proposal; 216 Comments Received So Far

 

A significant number of written comments from Florida governmental entities were among the 216 submissions received so far today, April 12, 2017, in response to a request for feedback on a Federal Emergency Management Agency (“FEMA”) concept to implement a Public Assistance deductible that would condition states’ receipt of FEMA reimbursement for the repair and replacement of public infrastructure damaged by a disaster event.

The comment deadline is open until 11:59 p.m. tonight (ET).

On January 20, 2016, FEMA published an Advance Notice of Proposed Rulemaking (“ANPRM”) seeking comment on a Public Assistance deductible concept.  The ANPRM provided a general description of the concept that many commenters found insufficient to provide meaningful comment.  In an effort to offer the public a more detailed deductible concept upon which to provide additional feedback, FEMA issued a second ANPRM that included a methodology for calculating deductible amounts based on a combination of each state’s fiscal capacity and disaster risk, a proposed credit structure to reward the state for undertaking resilience building activities, and a description of how the program would be implemented.

To view the entire docket and supporting documents, including written comments, click here.

Hyperlinks to comments received from Florida and other national entities of interest are below:

Comment Submitted by Eric Poole on behalf of Florida’s 67 counties

• Comment Submitted by John Sullivan, Broward County Public Schools
• Comment Submitted by Scott Clark, The School Board of Miami-Dade County, Florida

Comment Submitted by Evan Rosenberg, Florida Division of Emergency Management

• Comment Submitted by Charles Cyrille, Miami- Dade County Office of Emergency Management
• Comment Submitted by Steve Detwiler, Miami- Dade County, FL Office of Emergency Management
• Comment Submitted by Kimberly Prosser, Brevard County Emergency Management

Comment Submitted by Eve Rainey, Florida Emergency Preparedness Association

Comment Submitted by National Conference of State Legislatures

Comment Submitted by Frank Nutter, Reinsurance Association of America

Comment Submitted by Tom Karol, The National Association of Mutual Insurance Companies (NAMIC)

Comment Submitted by James Whittle, American Insurance Association

Comment Submitted by Debra Ballen, Insurance Institute for Business & Home Safety (IBHS)

Comment Submitted by Julie Rochman, Insurance Institute for Business & Home Safety

Comment Submitted by Trina Sheets, National Emergency Management Association

 

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