What’s a state action plan for disaster recovery and why does it matter?

The state’s draft action plan for spending $57.8 million in federal disaster recovery funds was released last Thursday. The Texas General Land Office, which oversees the administration of the federal funds, has given the public 14 days to comment. Every day until Feb. 1, we’ll be asking fundamental questions about the action plan as we draft our own comments to the GLO to advocate for equitable disaster recovery for all Hurricane Harvey survivors. 

This week it will be five months since Hurricane Harvey made landfall in the Texas Gulf Coast. While much time has elapsed and billions of federal dollars have been spent on direct assistance for families’ immediate needs, the long-term recovery process post-Harvey is just beginning.

Disaster recovery happens in three main phases. The first is search and rescue. The second is the relief stage (transitional housing, hotels, short-term home repairs, FEMA applications and insurance claims). Finally, comes the long-term recovery phase. This third stage requires the State of Texas to propose to HUD a plan to spend federal funds to protect communities from future storms, improve neighborhoods, and invest in infrastructure that, for some neighborhoods has long been neglected or even denied. During the final recovery stage, the federal government ultimately will send billions of dollars to the State of Texas in HUD Community Development Block Grant funds to rebuild communities, invest in storm mitigation, build public infrastructure, and help survivors recover their homes.

The recovery is a long-term back-and-forth process between local governments, the state, and the federal government. Over the last five months, cities and counties have been speaking with state officials to discuss their communities’ needs for rebuilding. The State of Texas has been collecting data, preparing plans to allocate the federal funds, and waiting for a notice in the federal register that announces the allocation of federal funds for Texas, details the allowable uses for the funds, and sets out the regulations that are a condition of the State receiving and spending that money. Meanwhile, at the federal level, analysts and officials at the Department of Housing and Urban Development and FEMA have been collecting and analyzing data, too. HUD officials have also been hearing from advocates and state officials about Texas disaster recovery needs, and drafting that federal register notice.

The first Federal Register notice, published on Dec. 20,  has triggered the start of the long-term recovery phase. The notice provides the stipulations for $57.8 million in HUD funding. (Note, these are repurposed funds originally appropriated for rebuilding from the 2015 and 2016 floods. Texas is slated to receive another $5 billion in HUD funding. This second Federal Register notice for the larger allocation of funds has not been published.)

When the Federal Register notice is published, the state must prepare an “action plan.” The action plan tells HUD how the State of Texas wants to spend the funds, answers basic questions such as how local jurisdictions like counties and cities have been prioritized, how Texas has listened to stakeholders in its planning, and reports the scope of unmet need and distressed and impacted areas based on data that has been collected and analyzed over the last five months.

The General Land Office released a draft of its state action plan last week. You can read it here. This action plan might not seem significant — it’s for $57.8 million, a fraction of the $5 billion Texas is expecting soon. But it has major implications for how Texas will address the needs of impacted communities and survivors. This plan provides an outline for how Texas is looking at recovery: the state’s big-picture priorities as well as its understanding of need across the various regions. The citizen participation permitted on the action plan draft presents an opportunity for citizens to engage with the disaster recovery process and make their voices heard if they feel they have been left out or if their needs haven’t been met. For any action plan regardless of whether it’s $5 million or $5 billion, the state must listen to the input from the public and respond to it. While much of the language in the action plan can be convoluted and the process tends to be opaque, communities and the public have a right to know and have a voice in what the state plans to do to help survivors and their neighborhoods recover.

This time around the public only has 14 days to comment on the state’s draft plan. Advocates and some members of the public are currently combing through this document, analyzing the methodology and data sources, as well as the prioritization of some areas and neglect of others. Advocates like us are sending letters to the GLO, requesting access to the data the state uses to determine their priorities, and providing feedback on some of the suggestions or omissions in the plan. After the 14 days — on Feb. 1 — the state must respond to those comments. Texas then submits its plan to HUD, which will approve it (or not) within 45 days. If HUD approves the plan, Texas signs a grant agreement and the allocations to councils of government and local jurisdictions begin. HUD can, and often does, ask the state to make changes to the Action Plan based on citizen comments or HUD’s own analysis.

And that’s just for the $57.8 million. The same action plan and comment process will begin again after the next Federal Register notice.

Stay turned here for our daily updates on what we think is right and wrong about the Action Plan and be sure to read the plan yourself and speak out – it is your right (and we suggest your duty) as a citizen.