Homeland Security Grants: Not For Emergency Management, Part 3

Homeland Security Grants: Not For Emergency Management, Part 3

Maybe its time that state and local governments put their money where their mouth is and fund local emergency management as they do police and fire; maybe its time they stop gambling with their constituents’ lives – maybe its time they stop waiting for emergency management to become a federal priority. Because, as we laid out in parts one and two, Congress was never in love with emergency management, and left the dance with homeland security in 2001.

It is blatantly clear that preparing for natural and technological disasters is not a priority for the federal government. And many argue that the ball should not be in their court, and never should have been. Maybe the real problem lies in the fact that elected representatives at the state and local level give preparedness little more than lip service? If public priorities are illustrated by the dollars appropriated to a cause or program, then law enforcement and fire protection are filet mignon and emergency management is chopped liver.

"If public priorities are illustrated by the dollars appropriated to a cause or program, then law enforcement and fire protection are filet mignon and emergency management is chopped liver."

But, why is there a misconception that state and local Emergency Management Agencies (EMA) are flush with cash from the Homeland Security Grant Program (HSGP)? Well, it starts with the fact that the Federal Emergency Management Agency (FEMA) administers the program for the Department of Homeland Security (DHS). Hey, if FEMA’s sending money, it’s gotta be good for emergency management, right?

And who serves as the State Administrative Agency (SAA) for the HSGP? The state EMA, of course. The same as it is for the Emergency Management Performance Grant Program (EMPG), the Hazard Mitigation Assistance Program (HMAP), and the Emergency Planning and Community Right to Know Act (EPCRA) program.

But, being the SAA means only that one is the eligible entity to apply for and administer the grant, not how to divvy it up. You see, how the funds are allocated is dictated by the terms outlined in the grant agreement. And it is there that the HSGP departs from the core mission of emergency management.

HSGP Funding Opportunity Announcement

The HSGP is authorized by the Homeland Security Act of 2002, as amended. The Act requires that grant allocation decisions be “based upon risk.” And the Department of Homeland Security (DHS) defines risk as: “potential for an unwanted outcome resulting from an incident, event, or occurrence, as determined by its likelihood and the associated consequences.”

Now, could an “incident, event, or occurrence” not be a natural or technological disaster, such as a nuclear reactor meltdown or a hurricane? Sure! But, it goes beyond the definition of risk to how DHS determines risk.” In the HSGP Funding Opportunity Announcement (FOA), risk methodology is focused on three principal elements:

  • Threat – likelihood of an attack being attempted by an adversary;
  • Vulnerability – likelihood that an attack is successful, given that it is attempted; and
  • Consequence – effect of an event, incident or occurrence 

DHS’s risk methodology is intended to determine “the relative risk of terrorism faced by a given area,” not the threat of a tornado, hurricane, or dam failure. And when awardees complete their grant mandated threat analysis, they must “account for threats from domestic violent extremists as well as international terrorist groups and those individuals inspired by terrorists abroad.” 

"DHS’s risk methodology is intended to determine “the relative risk of terrorism faced by a given area,” not the threat of a tornado, hurricane, or dam failure."

In describing the three interconnected programs under the HSGP, it is again clear that the nexus of the HSGP is averting human-caused disasters – terrorism – and reducing the damage when attacks are successful:

  • State Homeland Security Program (SHSP): The SHSP assists state, Tribal and local preparedness activities that address high-priority preparedness gaps across all core capabilities where a nexus to terrorism exists.
  • Urban Area Security Initiative (UASI): The UASI Program assists high-threat, high-density Urban Areas in efforts to build and sustain the capabilities necessary to prevent, protect against, mitigate, respond to, and recover from acts of terrorism.
  • Operation Stonegarden (OPSG): The OPSG Program s supports enhanced cooperation and coordination among Customs and Border Protection (CBP), United States Border Patrol (USBP), and local, Tribal, territorial, state, and Federal law enforcement agencies.

The Haves & Have Nots

Most federal grant programs, including the EMPG, Public Health Emergency Preparedness Program (PHEP), and the Hospital Preparedness Program (HPP), are delivered using a population based funding formula. That is, there is a base amount for each awardee and then a multiplier is added based on a state’s population. Most argue that population based funding provides for a fair distribution of federal tax dollars back to the states. But, is it always the most effective? That's a debate for another day.

The Homeland Security Grant Program Funding is heavily weighed to supporting the 10 most populous regions in the country.

The HSGP breaks from the tradition of the EMPG, PHEP, and HPP grant programs in that it allocates dollars “based upon risk.” There is no doubt that it is a bit less objective process. And it opens the argument whether the value of a life in Oshkosh, Wisconsin is worth less than one in New York City. To illustrate how drastically different risk based funding is from population based funding, let’s compare allocations for the EMPG Program and the HSGP.

In explaining eligibility, the EMPG FOA states, “[a]ll 50 states, the District of Columbia, and Puerto Rico receive a base amount of 0.75 percent of the total available funding appropriated for the EMPG program… The balance of the funds appropriated for the EMPG Program funds is distributed on a population-share basis.” 

The emergency management performance grant program is distributed using a population based formula.

For FY 2015, Congress appropriated $350,100,000 for 58 EMPG grants to be offered to all 50 states, Washington, D.C., territories, and freely associated states. Given that the formula is legislatively defined and based on objective population data from the U.S. Census, the outcome is what it is. If one ranks the states in order of population, they have ranked them in order of EMPG allocation. Bada-Bing!

Unlike the EMPG, the HSGP contains three distinctly different programs, each with unique eligibility requirements and earmarked appropriations. The FOA outlines each program’s eligibility criteria as follows:

  • SHSP | $402,000,000 | 56 Eligible Awardees | Includes any state of the United States, the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands.
  • UASI | $587,000,000 | 28 Eligible Awardees | Eligible high-risk Urban Areas for the UASI Program have been determined through an analysis of relative risk of terrorism faced by the 100 most populous Metropolitan Statistical Areas (MSA) in the United States.
  • OPSG | $78,000,000 | 39 Eligible Awardees | Eligible sub-recipients under are local units of government at the county level and Federally-recognized Tribal governments in states bordering Canada, states bordering Mexico, and states and territories with international water borders. All applicants must have active ongoing United States Border Protection (USBP) operations coordinated through a U.S. Customs & Border Protection (CBP) sector office to be eligible for OPSG funding.

Of the three programs under the HSGP, only the SHSP has a legislative requirement that somewhat mimics the population-based funding formula of the EMPG Program. Well, at least from FEMA to the states. You see, unlike EMPG, HSGP sub grants for are not required to be routed to the local EMA. But, maybe that’s because the HSGP was never intended to be an emergency management program.

The EMPG, on the other hand, is textbook fiscal federalism – money is routed from the federal government to the state government to the local government – from FEMA to the state EMA to the local EMA. That's likely because it's intended to be an emergency management program.

Karl Schmitt, MPA

Karl Schmitt, MPA

Karl is the Passionate Founder & CEO of bParati. He is on a mission to build a national network of effective, sustainable healthcare coalitions. More...

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