Proposal for a Comprehensive Preparedness Grants Structure
The report, a “Proposal for a Comprehensive Preparedness Grants Structure” follows last summer’s NEMA report titled “The Homeland Security Grant Program – Keeping a Promise to the Nation.” According to the NEMA web site , this effort was spurred by a desire to provide an alternative to calls to Congress to “please don’t cut funding”.
The calls to not cut funding fell on deaf ears as Congress proceeded to cut the budget sharply. Homeland security grants were targeted for a disproportionate level of cuts, down nearly two thirds from FY 2010.NEMA and the International Association of Emergency Managers (IAEM) have consistently lobbied rather successfully for maintaining EMPG funding levels while not lobbying for HSGP.
The NEMA document indicates that they intended to focus on principles and values with a suggested concept for grant reorganization . This was, according to the report, to provide grantees “increased flexibility and more comprehensive accountability to Congress”. Under the proposal, states would be awarded three allocations from DHS: Emergency Management Performance Grants (EMPG), a new homeland security “cadre grant”, and a project-based “investment and innovation grant.”
“The state is awarded three allocations from DHS, including one for EMPG, one for the new homeland security cadre grant, and one for the new investment and innovation grant.”
The NEMA document goes on to state that the outcome of this new system will result in several advantages over the existing system. “All current grant applicants remain eligible to receive funding including ports, nodes of transportation, and urban areas. This new system ensures all grantees are integrated within the state and local THIRA process as well as national priorities.”
The recommended changes include putting these grants in the hands of state officials to allocate. Homeland Security Advisors (HSAs), State Administrative Agencies (SAAs), and emergency management directors have, according to the report, “far more visibility on allocation of funds within the state and how projects and jurisdictions are working together for maximum efficiency of the taxpayer dollars.”
You will need to read the report to get the full picture but we’ve taken a look and have some observations.
Grant Life Cycle
The proposal keeps much of the core homeland security grant planning process (life cycle) including the state homeland security strategy, a comprehensive Threat Hazard Identification Risk Assessment (THIRA) and assess ment s of current capabilities to determine requirements and evaluate recent progress. However, the recommendation does not seem to stress risk or capabilities-based decision making regarding allocations.
While this may be a stretch on the definition of cadre, the cadre grant would maintain the existing EMPG program (helping staff emergency management offices).
The proposed reorganization would result in the first two allocations received by the state being for staff -based activities such as planning, assessments, grant administration, and other homeland security and emergency management functions. The emergency management responsibilities would continue to be administered through EMPG. The homeland security cadre-based grant would be very similar to EMPG in construct and administration, but managed through the HSA.
“Just as EMPG has been proven to reduce the reliance on federal assets during disaster response, this new construct would achieve the same benefit in the prevention of terrorism.”
A majority of the funding through this proposed system would go toward investment grants made through a single allocation to the state. Unlike the current system which the NEMA report describes as “narrowly focused” and “uncoordinated”, the proposed system would be project-based. The SAA and local governments would apply for funding based on their THIRA and preparedness strategy. These applications would be reviewed by a multi-disciplinary advisory committee, and the SAA makes awards as appropriate.
This last step of SAA making awards removes this responsibility from FEMA and places it at the state. This, the report says, will provide “stability for jurisdictions currently operating in the Urban Area Security Initiative (UASI), ensuring a city can never again “fall off the list.”
But the report treats Tier 1 UASIs differently. “Due to their significant security issues, Tier 1 UASI’s would continue to be funded directly. This will ensure every urban area will be part of the THIRA and application process and no one is left out.”
In the end, this report appears to have merit but more discussion and stakeholder involvement is warranted before the system is overhauled. With grant guidance due out in February, it is unlikely that any changes, not already in the works at FEMA, will be made for the next cycle. Even without changes, the State Homeland Security Grant Program can address many of the goals laid out in the report.