I blogged on this earlier this week and I hit a nerve on several fronts. Now the National Association of Counties and the International Association of Emergency Managers (IAEM) have sent a joint letter, dated March 6th, to the FEMA Administrator asking that any proposal to share EMPG funds with nonprofits be withdrawn.
State and local emergency managers were celebrating the expansion of EMPG funding while other Homeland Security grant programs were contracted significantly in the 2012 budget. Now they see the "potential" for this funding to be reduced significantly because there are more faces to feed at the grant table.
What would be interesting to know is who put the language in the guidance anyway? They certainly didn't know the temperature of the local water and how organizations would react. I'm betting FEMA will back-peddle quickly since they are trying to build support and have been successful for the last few years. In my mind they stubbed their toe on this one--ouch!
The text of the NaCo and IAEM President's letter is below:
Dear Administrator Fugate,
On behalf of the Nation’s elected county officials and the Nation’s city and county emergency managers, we are contacting you regarding a matter of great concern in the FY 2012 Funding Opportunity Announcement (FOA) for the Emergency Management Performance Grant (EMPG).
The EMPG program has formerly been very straightforward – it was designed to provide financial support to assist in developing basic capacity for emergency management among those statutorily charged with emergency management responsibilities at the State and local government levels. The state has been the grantee and local government emergency management agencies and tribes have been the sub grantees.
However, page 19 of the FOA for FY 2012 EMPG contains the following language (emphasis added):
“In support of engaging stakeholders at all levels, EMPG Program funds may be sub granted to non-governmental emergency management stakeholder entities such as non-profits, public and private universities, hospitals, faith-based entities.”
Our source of concern lies with this unprecedented expansion of sub grantees for EMPG that includes many of our long-time partners, allies, and supporters in providing emergency management services to our whole community. This expansion of sub grantee eligibility will place those statutorily charged with emergency management responsibilities (typically state, local, and tribal governments) in an inappropriate and unseemly competition for scarce EMPG resources with our long-standing partners, supporters, and allies.
It is our belief that this expansion could result in two very negative outcomes. The first we envision would be the erosion of the “whole of community” approach endorsed by FEMA due to inappropriate and unseemly competition between friends, allies, and supporters. The second is the potential creation of a “pay to play” atmosphere among allies, potentially creating unbridgeable gaps between us.
In addition to the potential negative outcomes mentioned above, we further believe the language expanding the pool of eligible sub grantees is in conflict with the federal authorization for EMPG (emphasis added):
Public Law 110-53, The Act to Implement the Recommendations of the 9/11 Commission (referred to as the 9/11 Act), amended the Post Katrina Emergency Management Reform Act to include the following language: “The Administrator of the Federal Emergency Management Agency shall continue implementation of an emergency management performance grants program, to make grants to States to assist State, local, and tribal governments in preparing for all hazards, as authorized by the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5121 et seq.).
In closing, I would like to re-confirm to you that NACo, IAEM-USA, and their members stand behind you and FEMA in wanting to provide emergency management services to the whole of our communities. We would ask that the FY 2012 guidance provision generating the concerns outlined above be rescinded in writing by FEMA at its earliest opportunity.
