NCIL Expresses Concern with National Response Plan

April 6, 2007

Al Fluman
Acting Director
National Incident Management System Integration Center
Federal Emergency Management Agency
Department of Homeland Security
Sent via email: NIMScomments@hsi.dhs.gov

Dear Mr. Fluman:

I am writing on behalf of the National Council on Independent Living (NCIL) about the Revised National Incident Management System (NIMS) Document. We appreciate the opportunity to comment on this comprehensive review of the National Response Plan (NRP) and National Incident Management System (NIMS).

NCIL is the oldest cross-disability, national grassroots organization run by and for people with disabilities. NCIL's membership includes centers for independent living, statewide independent living councils, people with disabilities, and other individuals and disability rights organizations. As a membership organization, NCIL advances independent living and the rights of people with disabilities through consumer-driven advocacy. NCIL envisions a world in which people with disabilities are valued equally and participate fully.

NCIL commends NIMS for its outreach to the disability community, among others, as part of the effort to ensure that the Nation can effectively and efficiently prepare for, prevent, respond to, and recover from any type of incident. The DRAFT Upgrade version 2 of March 2007 is an improvement over the first draft. However, NCIL remains concerned about several issues. These include:

Guidance on Housing Assistance
NCIL recommends that no more than five days after declaration of disaster, the Federal Emergency Management Agency (FEMA) be required to issue public guidance in a simple, concise manner and in alternate formats that would:

• Clarify all types of housing assistance available under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (the Stafford Act) to households affected by a major disaster;
• Specify requirements that households must meet to be eligible for the different types of housing assistance, including requirements for continuation of housing assistance provided, including step-by-step procedures for applying for such assistance, and;
• Publish the guidance on the FEMA Web site and make the guidance available in accessible, alternate formats to any person or family requesting housing assistance. This includes providing alternate format to people with low vision and/or people with low-English proficiency.
  
  

  Accessible Direct Housing Assistance
  As the Gulf Coast hurricanes proved, FEMA housing remains inaccessible to many people with disabilities and even to people who sustained injuries as a result of the hurricanes. More needs to be done to ensure that people with disabilities, including persons with invisible disabilities, such as vision and hearing loss and multiple chemical sensitivity, obtain accessible housing in the wake of losing their home. NCIL recommends that:

  • Not less than 7% of direct housing assistance units should be made accessible and reserved for  persons with mobility impairments;
  • Not less than an additional 2% of such units should be accessible and reserved for persons with hearing or vision impairments, and;
  • Not less than 1% of these units should be accessible and reserved for persons with mobility and vision or hearing impairments.
  • All units should not contain formaldehyde and other toxic vapors. Units must meet Environmental Protection Agency and Occupational Safety and Health Administration standards.

  Equitable Provision of Social Services Regardless of Classification of Emergency Shelter
  Functional needs shelters and general population shelters are the two general categories of shelters after disasters. Often, different resources are available to people at different shelters. Access to social services and information about housing opportunities should be provided in an equitable manner to all persons, without regard to the category of emergency shelter and the agencies responsible for administering the shelter.

  NCIL supports the concept of planning for people based on functional abilities and limitations rather than using labels such as "special needs" to categorize people with meaningless terms. This is especially important in planning for "general population” shelters where many people with disabilities could function effectively if properly planned.

  Thank you again for your consideration. NCIL and our members look forward to working with you to ensure swift implementation of this plan. Please do not hesitate to contact Deb Cotter, of my staff at Deb@ncil.org or (202) 207-0334.
  

  Sincerely,
  
  
  John Lancaster                                                        Kelly Buckland
  Executive Director                                                    President