[NFBSF] Fwd: Review of FEMA Council Final Report Disability Impacts

[Sheela Gunn]

Hi, All,

I got Helen's permission to send this far/wide. Please amplify?
S
-------- Forwarded Message --------
Subject: Review of FEMA Council Final Report Disability Impacts
Date: Wed, 13 May 2026 10:48:35 -0700
From: Helen Walsh <branach at comcast.net>
To: Sheela Gunn <sgunn at thecil.org>
CC: Michai Freeman <mfreeman at thecil.org>



Yesterday’s Partnership for Inclusive Disaster Strategies meeting 
included a deep discussion of the FEMA Review Council Final Report. What 
stood out to me most is how the report dismantles the planning systems 
that protect people with access and functional needs. Below is my Review 
of the FEMA Review Council Final Report (May 7, 2026), with page numbers 
added for clarity.


The FEMA Review Council Final Report leaves out major issues that affect 
disabled people. When we look at the report through disability justice, 
disability rights (the Americans with Disabilities Act and Section 504 
of the Rehabilitation Act), and Access and Functional Needs frameworks, 
it becomes clear that the report does not address the needs, rights, or 
real experiences of disabled people during disasters. The report does 
not meaningfully mention disabled people, people with Access and 
Functional Needs, the Americans with Disabilities Act Title II 
requirements for state and local governments, or the specific ways 
disasters harm disabled people. This omission would cause real harm if 
the recommendations were put into practice.


The report says it is based on “the lived experiences of those directly 
impacted,” but disabled people are not named anywhere as a group that is 
disproportionately harmed in disasters.

On page 4, the report lists who they engaged with: “11,708 public 
submissions…listening sessions in 13 cities…and four listening sessions 
with tribal nations.” Disabled people, disability organizations, Centers 
for Independent Living, and Access and Functional Needs partners are not 
mentioned.

Also on page 4, the report lists “vulnerable populations like renters, 
low-income families, and tribal nations,” but does not include disabled 
people. This is a serious omission.


 From a disability justice perspective, the report fails to recognize 
that disabled people are more likely to die or be harmed in disasters, 
face barriers to evacuation, sheltering, communication, transportation, 
and recovery, and need disability-led planning and accessible systems. 
The report’s focus on “individual responsibility” for disaster 
preparedness does not work for disabled people.

On page 5, the report states: “It is the responsibility of every 
American to embrace their individual responsibility to lessen this 
burden by being prepared for disasters.” Disabled people cannot 
individually fix inaccessible shelters, transportation, housing, or 
power-dependent medical needs.


The report does not reference Access and Functional Needs frameworks 
such as the CMIST model (Communication, Maintaining Health, 
Independence, Safety/Support, and Transportation). It does not address 
accessible communication, accessible evacuation, accessible sheltering, 
or disability-inclusive planning. It also does not mention the legal 
requirements of the Americans with Disabilities Act Title II or Section 
504 of the Rehabilitation Act, even though the report proposes shifting 
major responsibilities to states and local governments.

On page 5, the report states: “Disaster response should be locally 
executed, state or tribally managed, and federally supported.”

On page 6, it says: “Return leadership for emergency response and 
recovery to the States, Tribes, and Territories.” These shifts are made 
without acknowledging civil rights obligations. Without federal 
enforcement, disabled people will be left behind.


The report proposes major changes to FEMA programs, such as replacing 
Individual Assistance with a single direct payment, shifting sheltering 
responsibilities to states, and reducing federal oversight.

On page 9, the report recommends: “Consolidate existing programs into 
one direct payment to survivors whose homes are uninhabitable.” This 
ignores disability-specific needs such as durable medical equipment, 
home accessibility modifications, personal assistance services, 
accessible transportation, communication access, and backup power for 
medical equipment. Also on page 9, the report proposes: “Transfer 
evacuation and temporary emergency sheltering responsibilities to state, 
tribal, and territorial governments.” This is dangerous for disabled 
people because states vary widely in accessibility and compliance with 
disability rights laws.


The report also limits FEMA’s role in long-term housing.

On page 9, it states that FEMA should “focus…on emergency and temporary 
housing…instead of long-term housing.” Disabled people often need 
long-term accessible housing solutions after disasters. Removing federal 
support harms disabled survivors.


The report proposes a new Public Assistance model called RAPID, which 
gives states full control over eligibility and project decisions.

On page 10, it states: “States…would gain the autonomy to manage the 
funding, to include determination of project eligibility.” States have a 
long history of failing to comply with disability rights laws. Without 
strong federal civil rights enforcement, this creates a high risk of 
discrimination.


The report also proposes a parametric model for disaster funding that 
ignores disability impacts.

On page 10, it states that funding would be based on “pre-defined, 
objective event criteria like wind speed or earthquake magnitude.” This 
ignores slow-onset disasters, power outages, heat waves, and cascading 
failures that disproportionately harm disabled people.


The report’s recommendations for the National Flood Insurance Program 
ignore the fact that disabled people are more likely to live in 
low-cost, flood-prone housing and need accessible rebuilding and 
replacement of medical equipment.


The report talks about partnerships with private companies, faith-based 
groups, and nonprofit organizations, but it never mentions 
disability-led organizations such as Centers for Independent Living or 
Developmental Disabilities Councils.

On page 13, the report says the agency should promote a “Whole 
Community” approach, but the groups listed do not include disability-led 
organizations. This contradicts the “Whole Community” approach the 
report claims to support.


The report proposes “state performance metrics” that determine how much 
federal funding a state receives, but none of these metrics include 
disability-related requirements. There is no evaluation of accessible 
emergency alerts, accessible shelters, disability-inclusive planning, 
disability-inclusive training exercises, or disability-inclusive 
mitigation. This gives states no incentive to include disabled people.


The report also recommends shrinking FEMA, reducing federal oversight, 
and shifting responsibilities to states and local governments. This 
ignores the need for consistent federal standards, federal civil rights 
enforcement, and federal disability expertise. Disabled people rely on 
federal protections because state and local systems are often 
inconsistent and inaccessible.


A disability-just and legally compliant version of this report would 
need to include Access and Functional Needs frameworks, Americans with 
Disabilities Act and Section 504 requirements, disability-specific 
funding categories, disability-led organizations as required partners, 
disability-related performance metrics for states, strong federal 
enforcement, and recognition that direct payments cannot replace 
disability-specific supports.


In summary, the report’s recommendations would weaken protections for 
disabled people, increase inequities, and undermine civil rights. 
Disabled people are left out of the analysis, the recommendations, and 
the vision for the future of FEMA. A disability justice approach 
requires centering those most impacted, ensuring collective access, and 
refusing to abandon disabled people. This report does the opposite.


Link to the report Fema Review Council Final Report:
https://www.dhs.gov/sites/default/files/2026-05/26_0507_fema%20review%20council_final%20report.pdf 
<https://www.dhs.gov/sites/default/files/2026-05/26_0507_fema%20review%20council_final%20report.pdf>

Helen Walsh
UCC Disaster Ministries
Accessibility and Inclusion Advisor


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