NLIHC submitted comments on behalf of its Disaster Housing Recovery Coalition (DHRC) on July 25 regarding a recent request by FEMA for information regarding the Community Disaster Resilience Zone (CDRZ) program and the National Risk Index (NRI). The request, initially published on May 26, detailed several changes proposed by FEMA concerning the NRI, which is a formula-based analysis of resilience by census tract across the U.S. FEMA sought information from stakeholders regarding how to update the index to ensure that it adequately captures future disaster risk, as well as other ways to improve its formula to better reflect community-level risk.
The request also asked for feedback regarding the new CDRZ program, which was created by legislation supported by NLIHC and the DHRC in 2022. The CDRZ program would involve selecting census tracts around the country based on their vulnerability to disasters and then target these areas for FEMA assistance that would be used to plan and implement mitigation and resilience projects, decreasing communities’ risk of adverse disaster impacts.
In its comments regarding the NRI, NLIHC focused on the reliability of the model, suggesting that the formula does not yet provide a fully appropriate map of risk across the country. The letter pointed to multiple areas where the NRI’s conclusions seem to be incorrect, given community vulnerabilities on the ground. It also requested that the agency publish details regarding potential errors in its database – a common practice among other federal agencies.
Regarding the CDRZ program, NLIHC’s comments covered a range of topics. These topics included the need to target disaster resilience projects toward those households most likely to be severely impacted following a disaster, ensuring that community control mechanisms are created during the planning of any potential mitigation and resilience project, and guaranteeing that, in cases where household displacement is unavoidable, any displaced households are provided robust relocation assistance to ensure they can access permanent housing.