Turning the tide toward equity: making federal flood programs work for low-income people

American Flood Coalition
American Flood Coalition
7 min readMay 5, 2020


In the United States, 99% of counties experienced at least one flooding event in the last 25 years. However, flood waters do not impact all people equally.

In this three-part series, the American Flood Coalition examines inequity in flooding and disaster recovery policies, creating a framework for nearly a dozen modifications that would improve outcomes for all Americans. This first post explores program eligibility. We consider renters and other marginalized populations in our next post and close our series with a discussion on application complexity.

Over two years after Hurricane Harvey, Ruth Ortiz is still struggling to get by. Ortiz was renting a home in Victoria, Texas, when Harvey hit and destroyed most of her belongings.

Since then, Ortiz’s life has been in flux. Unable to find an affordable home to rent, she has moved several times and struggled to provide for her family. The one $2,400 check Ortiz received from the government immediately after the disaster did not account for the new reality of life after Harvey. She said, “I just felt left behind.”

Ortiz’s experience tells a larger story: across the country, people of color, low-income people, and renters are disproportionately affected by flood disasters. And with insufficient support from federal aid programs, what happens one night can have effects that last for years. So, why are these communities constantly left behind when disaster strikes? In this post, the American Flood Coalition explores the answer to that question — and offers solutions.

Systems at the root of the problem

To fully understand why this happens, we must look at structures that have existed for decades. The country’s economic, political, and social systems were not designed with the well-being of these communities in mind. And when hurricanes arrive and the flood comes, this systematic failure reveals itself, as it did in Ruth Ortiz’s story.

Over the past century, class and racial discrimination in lending, housing, and other sectors has created structural inequality, or an uneven allocation of power, that harms low-income communities and communities of color. For decades, banks denied loans to neighborhoods deemed risky — today, 74% of the neighborhoods redlined 80 years ago are now low-to-moderate income, and 64% are neighborhoods primarily occupied by people of color.

This disinvestment has a lasting legacy. People with lower incomes and people of color are already more likely to live in neighborhoods that have failing infrastructure and receive less public and private investment, so when floods arrive, these people are disproportionately at risk for an incomplete or prolonged recovery. And as disasters increase in frequency and intensity, this problem affects more and more disadvantaged Americans.

Federal disaster programs are in place to ease the burden for those affected. But federal disaster programs can actually worsen structural inequalities, leading to slower recoveries for vulnerable populations. A recent study found that in counties with disaster damages of at least $10 billion from 1999 to 2013, White households gained an average of $126,000 in wealth, while Black and Hispanic households lost an average of $27,000 and $29,000, respectively. The study determined that federal post-disaster assistance contributes to rather than mitigates this phenomenon.

Evacuees in Port Arthur, TX, wait for a rescue boat. They were forced to leave home during Hurricane Harvey. Source: Getty Images North America.

Program eligibility and requirements leave out low-income communities

Restrictions meant to determine eligibility for government funding often exclude those who need it most. Four federal disaster program elements contribute to inequity.

Benefit-cost ratios favor wealthy cities and neighborhoods. The U.S. Army Corps of Engineers (USACE) — the premier federal agency charged with building and maintaining flood mitigation infrastructure — significantly incorporates property value into their benefit-cost analysis, by which they approve and prioritize projects. This means that wealthy urban areas with higher property values are deemed more worthy of protection, because they perform better on the Corps’ analysis than poorer cities and rural areas do. For example, this analysis disadvantaged Cedar Rapids — a city with relatively low property values — when it sought Corps funding after disastrous flooding in 2008. The disparity between the Cedar Rapids levee and flood wall projects’ benefit-cost ratio of 1.1 and others around the country in the 4 to 5 range is cited as the reason why it ultimately took over a decade to secure pledged funding. Within Cedar Rapids, the benefit-cost analysis favored projects on the commercial and more affluent east side of the Cedar River, giving them a just-high-enough-to-pass benefit-cost ratio of 1.1, over projects on the west bank that did not meet the threshold for funding at all. USACE and other agencies building or funding pre-disaster infrastructure could contribute to a future of equitable investment by proactively modifying metrics that determine project priority — such as benefit-cost ratios — so that they value equity considerations more and property values less.

Federal agencies fail to recognize heirs’ property. The Federal Emergency Management Agency (FEMA) and other federal agencies often do not recognize heirs’ property, land that is informally passed down between generations. One study estimated that 41% of Black-owned land in the Southeast can be considered heirs’ property. This form of land ownership is particularly common among Southern African American Settlement Communities, including the Gullah Geechee people who live in the barrier islands of the Carolinas, Georgia, and Florida. After Hurricanes Katrina and Rita, ~20,000 property owners were denied assistance from FEMA and U.S. Department of Housing and Urban Development (HUD) programs because they couldn’t show clear titles to their property. Though FEMA has relaxed its standards for property documentation, heirs’ property is still particularly vulnerable in the event of disasters.

Source: Getty Images North America.

HUD damage thresholds favor wealthier households. A substantial portion of post-disaster funding comes as HUD Community Development Block Grants for Disaster Recovery (CDBG-DR). To meet HUD’s requirements to receive funding after disasters that occurred in 2017, 2018, or 2019, a home was required to have real property FEMA-inspected damage of at least $8,000, personal property damage of at least $3,500, or flooding over 1 foot. Homeowners with a lower damage estimate were ineligible for the funds. Renters with less than $2,000 in property damage were also excluded. Many low-income households fall beneath these thresholds simply because their households and belongings are not worth much on the open market. As a result, following Hurricane Harvey, nearly two-thirds of very low-income households in Texas were cut out of the population considered to have unmet needs.

FEMA Individual Assistance standards lead to low grant amounts and disproportionate rejections for low-income applicants. The FEMA Individual Assistance (IA) Program, which can provide grants for home repairs, does not adequately meet the needs of low-income people. IA is not intended to restore homes to their pre-disaster conditions. Rather, the Stafford Act empowers FEMA to provide assistance to restore a home to “a safe and sanitary living or functioning condition.” This low benchmark is reflected in the data: the average grant for an individual or household after Hurricane Harvey was $4,300, far below the maximum allowable amount of $34,000. This low standard is disproportionately burdensome for low-income households, who often do not have the additional savings or resources to fill the gap between the grant amount and what restoration to pre-disaster conditions would cost.

In addition, FEMA standards lead to disproportionate outright rejections for low-income applicants. Of the 741,000 Texas applicants rejected after Harvey, applicants earning salaries of less than $30,000 accounted for 48% of denials even though they made up only 28% of applications. A few denial codes, including “Missed Inspection” and “Occupancy not Verified,” are disproportionately used to reject low-income households.

Understandably, low-income individuals rarely appeal their rejections. Because FEMA rarely specifies the rationale for rejection (the full inspection files must be formally requested), it can be challenging for individuals to make their case without the help of a lawyer. Low-income households receive adequate professional legal help for only 14% of their civil legal problems, so it is unsurprising that low-income applicants typically do not write back when rejected. Low-income households may not have access to other recovery funds, so they may feel the effects of the storm for a long time before they can make repairs.

Low-income Americans need government disaster assistance most; however, because of tight eligibility requirements and out-of-reach thresholds, they are often excluded from federal funding. Federal agencies should, therefore, reduce or modify program requirements — from formal property ownership documents to high damage thresholds — to enable a more equitable disaster recovery. Our next post in the series focuses on ways federal agencies can improve access to disaster funding for renters, unbanked populations, and non-English speakers.

This post was authored by Jasmine Butler, Winter Strategy and Outreach Intern, Summer Modelfino, Senior Strategy Associate, and Caroline Resor, Strategy Associate. It was reviewed by Senior Advisors Chauncia Willis, social equity and disaster recovery expert, and Joyce Coffee, climate adaptation specialist.

The American Flood Coalition is a nonpartisan group of cities, elected officials, military leaders, businesses, and civic groups that have come together to drive adaptation to the reality of higher seas, stronger storms, and more frequent flooding through national solutions that support flood-affected communities and protect our nation’s residents, economy, and military installations. The Coalition has over 200 members across 17 states.

Cities, towns, elected officials, businesses, and local leaders wishing to join the American Flood Coalition or read more about the organization’s work can visit the Coalition’s website (floodcoalition.org) to find out more.



American Flood Coalition
American Flood Coalition

A nonpartisan group of political, military, business, and local leaders that work together to drive adaptation to the reality of flooding and sea level rise.