June 8, 2026
The President’s Council to Assess the Federal Emergency Management Agency
U.S. Department of Homeland Security
Washington, DC 20528
Docket No. DHS-2026-0067
Re: Final Report: The President’s Council to Assess the Federal Emergency Management Agency (FEMA)
Dear Members of the FEMA Review Council,
National Taxpayers Union, the nation’s oldest organization representing the interests of taxpayers, appreciates the opportunity to comment on the Final Report of the FEMA Review Council. We strongly agree with the general concept guiding the report: that Americans should “embrace their individual responsibility” to lower heavily increasing burdens on taxpayers in the provision of both federal disaster response and flood insurance.
The current system of federal disaster response encourages state and local governments to both underinvest in building disaster response capacity, as well as underprepare for the inevitable occurrence of major weather events by failing to build more resilient communities and infrastructure. Also, the federal government’s direct provision of flood insurance limits entry of private insurance providers in the market by charging premiums below cost.
The FEMA Final Report attempts to address these issues by:
- Encouraging increased disaster response capacity at the state and local level,
- Moving the federal response to more of a supporting role,
- Building a more nimble and responsive federal response for more focused needs,
- Increasing the threshold for when a federal response is triggered to just major disasters,
- Reducing application burdens and streamlining program requirements and processes for both mitigation grants and disaster assistance to ensure those in need receive support in a timely manner,
- Revising federal flood maps to better incorporate risk data for use by individuals, the private flood market, and the federal government in assessing risk,
- Continuing the implementation of Risk Rating 2.0 in the National Flood Insurance Program (NFIP) to better align program premiums with actual costs, and
- Encouraging the private flood insurance market to grow, with the goal of eventually shifting more policies to a more nimble and responsive economic structure.
While we support most provisions described in this Final Report, we see significant challenges in the eventual implementation of these proposals. The incentive for members of Congress to provide ample federal support to disasters of all shapes and sizes remains high, and state and local governments will delay building capacity if they believe that the federal government will jump in as soon as disaster strikes. As for flood insurance, it is not politically popular to increase rates in a manner commensurate with risk on policyholders who are also voters. And some of the policyholders may need help to afford market-rate insurance, particularly during the transition to a fully privatized market.
We encourage the FEMA Review Council, as it moves to advise the Department of Homeland Security and Congress on implementation of these provisions, to also keep a realistic view of the path forward, understanding that there are real people and real communities affected by these changes. Taxpayers will greatly benefit from the implementation of the provisions in this Final Report, but implementation will never happen unless an approach is adopted that prioritizes the need for fiscal responsibility above the political considerations guiding policymakers.
Thank you for your efforts in drafting a Final Report that, if implemented, will finally start lowering the costs to taxpayers from ever-increasing federal disaster recovery and flood insurance expenses. We look forward to supporting your efforts to move these provisions forward. If you have any questions, we would welcome the opportunity to engage on these timely and important issues.
Sincerely,
David Timmons
Senior Policy Manager
National Taxpayers Union
dtimmons@ntu.org