To achieve an equitable recovery, we propose a fairer way to determine needs of Hurricane Harvey survivors

When the methods used to determine needs of hurricane survivors favor higher income people and communities, the process of recovery and rebuilding will favor higher income people and communities.

The only way to rectify a process skewed toward survivors with higher incomes rather than the most vulnerable is to make the methods more equitable.

Equity does not mean equality. Take a look at the image below.

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Artist: Angus Maguire

It illustrates how different people are approaching the same situation with various levels of advantage. In the image, the tallest person has the best access to the view of the ballgame while the shortest has no view. If you give them an equal boost, the shortest among them still has no view. But provide an equitable boost, and everyone can see.

Think of recovering from a disaster similarly. People at various points across the income spectrum in Texas experienced damage to their property and homes because of Hurricane Harvey. Whether the survivor’s house is worth $1 million or $50,000, or whether they’re a renter or homeowner, torrential rain, flooding and the aftermath have disrupted or uprooted their lives. Most people will need a boost to recover — and we as advocates for the most vulnerable and for communities of color, believe an equal boost is not the answer. As resources are finite after a disaster, it is important to prioritize those with fewer resources to recover.

Disaster recovery dollars allocated by the U.S. Department of Housing and Urban Development are intended to primarily benefit low- and moderate-income communities. The State of Texas, a grantee of the federal housing agency, must then find a way to distribute these funds to ensure that their plans meet the needs of low-income communities.

But in order for communities in need to be factored into the allocation fairly, the assessment of need must be rooted in a process that determines the needs of those with fewer assets or less of an advantage adequately.

In a letter submitted to the General Land Office, which administers hurricane recovery for Texas, our staff proposed a methodology that we think is more equitable than the current methodology.

Currently, the General Land Office concludes that some of the lowest-income survivors of Hurricane Harvey have no unmet need. This is because the GLO is making calculations based on what is called “FEMA-verified loss” — the loss that a hurricane survivor sustained, according to FEMA.  The determination, then, is based on the impact on people’s property, rather than the impact on the people themselves. Take a look at the disparity in FEMA-verified loss in the table we included in our letter to the GLO:

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ELI is extremely low income, about 30 percent of median family income. The next band is 50 percent of area median income, followed by 80 percent of area median income. LMI stands for Low- to moderate-income — the bands in the first three rows are considered LMI households.

The table above shows that, on average, the more affluent a survivor of the hurricane is, the higher the value of their losses. Based on this, the GLO’s methodology directs a larger amount of federal dollars to higher income people. In order to be considered an unmet need in this methodology, a household’s FEMA-Verified Loss must be at least $8,000 for owners and $2,000 for renters.

However, the average verified loss for extremely low income owners is nearly $1,000 under this threshold, and results in nearly 70 percent of FEMA-eligible households to be overlooked in the GLO’s unmet need assessment.

For renters, despite the fact that the average FEMA-verified loss for all income groups is over the $2,000 unmet need threshold, 58 percent of FEMA-eligible extremely low-income renters and 54 percent of renters at 30-50 percent of the area median income are below this threshold and not considered to have unmet needs in the draft Action Plan.

We think the gap in this methodology needs to be addressed immediately.

We recommend to the GLO that analysts instead relate a household’s FEMA-verified loss to a household’s income in order to consider the level of impact on a household, rather than only the impact on lo their property. We recommend the following methods of calculation:

  1. Start with the established verified loss thresholds for unmet need determination of $8,000 for owners and $2,000 for owners.
  2. Calculate the percentage decrease between the average verified loss for households that are not low-moderate income and the average verified loss for each low- to moderate-income group.
  3. Calculate new unmet need thresholds for each income group, as well as the damage category thresholds, by reducing each threshold by the percentage calculated in number 2 above
  4. Recalculate the number of FEMA-eligible owner and renter households with unmet needs based on these new thresholds
  5. Based on the proportions of income groups represented using this methodology, assume that households not reporting income represent income levels at similar proportions to those reporting incomes and add the appropriate number of these unreported income households to each income group

Comments on this methodology and the need for equity in the State’s plan for recovery are accessible in full below.

(Research staff Charlie Duncan and Amelia Adams contributed to this blog post) 

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