Emergency Justification Memo

Emergency Approval for Revised Collection, 1660-0017 Public Assistance Information Collection

U.S. Department of Homeland
Security
Washington, D.C. 20472

October 31, 2023

MEMORANDUM FOR:

Richard Revesz
Administrator,
Office of Information and Regulatory Affairs,
Office of Management and Budget

THROUGH:

Eric Hysen
Chief Information Officer
U.S. Department of Homeland Security

FROM:

Alexandra Travis
Chief Administrative Officer
Mission Support
Federal Emergency Management Agency

SUBJECT:

Digitally signed by
ALEXANDRA TRAVIS
04'00'

Emergency Approval Request of Revised Office of Management
and Budget (OMB) Collection 1660-0017, Public Assistance
Program in Support of Non-congregate Sheltering Operations in
Maui, Hawaii.

The Federal Emergency Management Agency (FEMA) seeks to utilize the emergency process
for approval from the Office of Management and Budget (OMB) Collection to update
information collection 1660-0017 Public Assistance (PA) Program in accordance with FEMA
established policy on sheltering in the Public Assistance Program and Policy Guide (PAPPG),
Version 4 and the Emergency Non-Congregate Sheltering Memo (issued June 28, 2022).
Background
State, local, tribal, and territorial (SLTT) governments can request sheltering support services
after receiving an emergency or major disaster declaration authorizing PA emergency protective
measures. FEMA provides PA funding to SLTT governments for costs related to emergency
sheltering for disaster survivors. Typically, sheltering occurs in facilities with large open spaces,
such as schools, churches, community centers, or other similar facilities. However, there are
situations when the need arises to support survivors in non-congregate shelters, which are
locations where each individual or household has living space that offers some level of privacy
such as hotels, motels, or dormitories.

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Emergency Approval for Revised Collection, 1660-0017 Public Assistance Information Collection

The authority for non-congregate sheltering is provided by Sections 403(a)(3)(B) and 502 of the
Robert T. Stafford Disaster Relief and Emergency Assistance Act, Pub. L. No. 93-288 (1974), as
amended, and as codified at 42 U.S.C. §§ 5170b(a)(3)(B) and 5192 (Stafford Act). Section
403(a)(3)(B) of the Stafford Act specifically authorizes “search and rescue, emergency medical
care, emergency mass care, emergency shelter, and provision of food, water, medicine durable
medical equipment, and other essential needs, including movement of supplies or persons.”
DR-4724-HI – Lahaina Wildfire
Following the devastating wildfires in Lahaina, Hawaii on the island of Maui, thousands of
residents lost their homes and their way of life. The state is working with voluntary organizations
to coordinate emergency shelter with Maui County for disaster survivors, an effort funded by
FEMA. With the help of these organizations, Maui County and FEMA have assisted survivors
now staying in hotels where they can develop plans to return to their homes or other more
permanent residences.
Hawaii is experiencing a housing crisis which has become commonplace for many communities
across this nation. The scarcity of available rental resources and a severe lack of affordable
housing have created a critical issue for those affected by the Lahaina disaster. Many of these
survivors have deep-rooted ties to Maui and are further burdened by the high housing costs in
other areas of the county. Public housing resources are already stretched to their limits.
While the state establishes programs for implementation of other housing solutions, there is a
significant need for continuation of sheltering efforts in order to protect and sustain life. Due to
the extended period of time the sheltering is needed, the use of non-congregate sheltering is
critical so that survivors have a reasonable amount of privacy and comfort while sheltering as
they await other longer term housing solutions.
To ensure FEMA can track individuals and households transitioned into more permanent housing
solutions and the successful reimbursement to the state for the cost of sheltering survivors,
additional information needs to be collected to support non-congregate sheltering in Hawaii. The
following questions should be included into PA’s information collection 1660-0017:
•

Number of rooms

•

Check in date

•

Check out date

•

Person ID

•

Site ID for shelter

With the escalating demand for sheltering services and the recognition that sheltering periods are
likely to extend in the face of mounting housing crises, FEMA should make this data collection
change not only for Hawaii but as a standard practice for future disaster scenarios. This will
better equip FEMA to meet the evolving needs of survivors and communities during these
challenging times.
It is vital that FEMA implement the revision to PA’s information collection as soon as possible

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Emergency Approval for Revised Collection, 1660-0017 Public Assistance Information Collection

in response to DR-4724-HI. In accordance with the Paperwork Reduction Act (PRA) and the
Office of Management and Budget’s (OMB) implementing regulations at 5 C.F.R. § 1320.13: (1)
this information is necessary to the mission of the agency, (2) this information is necessary prior
to the expiration of time periods established under PRA, (3) public harm is reasonably likely to
result if normal clearance procedures are followed, and (4) an unanticipated event has occurred.
1. Information is Essential to the Mission of the Agency
Per FEMA policy, specific data points are provided to FEMA by state, local, tribal, and
territorial governments, also referred to as Recipients and Applicants. For non-congregate
sheltering activities, Recipients and Applicants collect information regarding the individuals and
households sheltered. This ensures that sheltering individuals and households with a
demonstrated need for continued emergency sheltering may be identified as eligible work.
FEMA uses the criteria below to determine eligibility of non-congregate sheltering work and
costs:
Each household must:
•

Be in an area declared for Individual Assistance (IA);

•

Be registered with IA for disaster assistance;

•

Have not requested to withdraw its IA registration;

•

Be able to document pre-disaster status as an owner or renter of the primary residence;
and

•

Have their primary residence determined not to be habitable.

When conducting non-congregate sheltering, Applicants use a reporting system to capture the
following data elements for individuals and households to ensure the eligibility of the work and
costs:
•

FEMA IA Registration Number

•

Head of household: First and last name with phone number (mobile or other)

•

Number of individuals in the household

•

Damaged dwelling: Street Address, City, State, Zip Code

•

Post-incident residence habitability status

The additional data points will help Recipients and Applicants track individuals and households
going in and out of sheltering and safeguarding no survivor slips through the cracks, ensuring
FEMA’s continued support.
2. Paperwork Reduction Act Timeframes
Given the number of individuals and households currently being sheltered, it would be
impracticable and contrary to the public interest to delay implementing this information
collection until after FEMA has completed the PRA process.

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Emergency Approval for Revised Collection, 1660-0017 Public Assistance Information Collection

It is imperative that those impacted by the disaster have an opportunity to receive assistance from
FEMA. To ensure individuals and families are supported during recovery efforts this information
is vital so that FEMA can be sure that those in shelters are equitably transitioned into permanent
solutions. Additionally, the Recipient and Applicant must be able to validate the number of
survivors staying in non-congregate sheltering to ensure they have enough rooms and that they
are not paying for rooms not in use.
3. Public Harm is Reasonably Likely to Result if Normal Clearance Procedures are
Followed
Without approval of this collection, Hawaiians will lose sheltering assistance desperately needed
by the survivors devastated by this event. FEMA registration data demonstrates survivors on
Maui have a clear need for aid. FEMA is working with the voluntary agencies and Hawaii
emergency management to relocate displaced residents to area hotels rather than congregate
shelters. This temporary solution will help residents feel more secure while long-term
accommodation plans are developed. Impacted individuals moved into hotels may continue to
receive meals, casework support and other disaster relief services for eligible households in the
months to come.
It is of utmost importance that those affected by this disaster have the opportunity to receive
FEMA and the state's assistance. To ensure that individuals and families receive the necessary
support during the recovery process, this additional data collection is critical. Additionally, it
enables the Recipient and Applicant to accurately assess the number of survivors staying in noncongregate sheltering. This information is vital to guarantee that there are sufficient rooms
available and that resources are not allocated to unused rooms, ensuring efficient and effective
recovery efforts.
4. An Unanticipated Event has Occurred
On August 8, 2023, wind-fueled wildfires roared through Lahaina, indiscriminately taking the
lives of more than 100 individuals. Thousands lost their homes. The housing shortage combined
with the high cost of labor and materials exacerbated the need to shelter survivors in noncongregate sheltering.
FEMA's registration data highlights the clear and urgent need for assistance among survivors on
Maui. In response, FEMA is collaborating closely with voluntary agencies and Hawaii's
emergency management to facilitate the relocation of displaced residents to local hotels instead
of congregate shelters. This temporary measure provides these residents with a higher level of
security as long-term accommodation plans are being developed. Those individuals who move
into these hotels may continue to receive essential services such as meals, casework support, and
other disaster relief assistance, ensuring continued support for eligible households in the months
ahead.
Conclusion
Following the normal clearance procedures for OMB approval will delay FEMA’s ability to
assist Americans and ensure they are equitably served. As explained in this memo, FEMA
certifies that this request meets the requirements of 5 C.F.R. § 1320.13(a) and it is vital that this

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Emergency Approval for Revised Collection, 1660-0017 Public Assistance Information Collection

revised collection be implemented immediately because: (1) this information is essential to the
mission of the Agency, (2) this information is necessary prior to the timeframes established
under the PRA, (3) public harm will result if normal clearance procedures are followed, and (4)
unanticipated events have occurred.
Thank you for your consideration.

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