iy Ane Stare oF Micntoaw GRETCHEN WHITMER OFFICE OF THE GOVERNOR GARLIN GILCHRIST It SOMERNOR LANSING | LT. GOVERNOR August 26, 2019 President Donald J. ‘Trump. ‘The White House Washington, D. C. 20500 Through: — Mr. James K. Joseph, Regional Administrator FEMA Region V 536 South Clark Street, 6th Floor Chicago, Illinois 60605 | Mr, President: | In response to the letter dated August 9, 2019, in which the Federal Emergency Management Agency (FEMA) Acting Administrator Pete Gaynor indicated, the State of Michigan has been denied the declaration of a Major Disaster and activation of Individual Assistance (IA) programs under the Robert, Stafford Disaster Relief and Emergency Assistance Act for the severe flooding that struck Wayne County on April 30, 2019. I hereby respectfully submit this letter of appeal, in accordance with the provisions set forth in 44 CFR § 206.46, requesting a reconsideration of that decision. My appeal of the decision is based on the following factors and additional information that | illustrate the severity, magnitude, and impact of the disaster and need for assistance to | households and individuals under the Stafford Act: | | Concentration of Damages the cities of Allen Park, Dearborn Heights, Detvoit, Zeorse, and Lincoln Park. Wayne County is the most populous county in the State of Michigan with 1,763,893 residents (per the 2018 US Census Bureau Population Estimates). The county and its residents are still | recovering from the 2014 Michigan Severe Storms and Flooding incident, which resulted in | Major Disaster declaration DR-4195 for the counties of Macomb, Oakland, and Wayne. For 1 very similar flooding incident, 2,269 impacted homes were identified in the Preliminary | Damage Assessment (PDA) with 73,411 IA applications processed. Over $170 million in Individuals & Households Program and Public Assistance Grants were approved. The PDA. for this year’s flood disaster identified 655 homes that were impacted by the flooding, due to | ‘Damages were particularly concentrated in urbanized areas of Wayne County, including | | [GEORGE W. ROMNEY BUILDING * 111 SOUTH CAPITOL AVENUE * LANSING, MICHIGAN 48900 ‘wrwimichigan.gov | e Omthe densely populated urban structure of the disaster area and based on past experience. From 2014, when over 30 times as many IA applications were processed as impacted homes were identified, it can be safely projected many more residents are negatively impacted by the flooding. The lengthy, ongoing recovery from the 2014 flooding is also a major impediment to the effective recovery from the 2019 flooding. ‘Wayne County is at the heart of the ten-county Detroit-Warren-Ann Arbor Combined Statistical Area (CSA), which accounts for approximately 54 percent of Michigan's population per US Census Bureau estimates. In addition to Major Disaster DR-4195, in the last five years these counties received one federal Emergency Declaration (Michigan Contaminated Water EM-375), and four State declarations of Emergency or Disaster were declared by my predecessor or myself for incidents ranging from flooding to extreme cold temperatures and infrastructure failures. The CSA also experienced numerous smaller- seale incidents for which jurisdictions did not seck a gubernatorial declaration or state assistance, even though they still incurred significant local impacts. Currently, the record high water levels of the Great Lakes are causing flooding in two CSA counties adjacent to Lake St. Clair. These conditions are anticipated to continue through at least 2020. Collectively, these past and ongoing incidents present an extraordinary strain on regional resources, which is a further hindrance to meaningful recovery from this disaster. ‘Trauma As discussed above, Wayne County was affected by flooding in 2014 that resulted in Major Disaster DR-4195. Many of the 2019 flood survivors were also impacted then, and some had not even completed their recovery from the 2014 incident when this disaster struck. The repetitive nature of this flooding incident coming on the heels of the long-lasting recovery from a previous flood has been particularly traumatic for the community. This trauma is inereased by the disproportional impacts to special populations (as discussed below), who are often the most severely affected, but are among the least able to recover from disasters due to their various access and functional needs. Special Populations ‘The socio-economic profile of Wayne County as a jurisdiction with a large socially vulnerable population further illustrates that affected populations will continue to struggle with the recovery from this disaster. A large share of the population of the county lives below the poverty threshold (23.7 percent, compared to 15.6 percent in Michigan and 14.6 percent nationwide). The median household income of county residents ($43,702) is significantly lower than statewide ($52,668) and nationwide ($57,652) figures. Therefore, many residents lack the financial resources to make necessary repairs to their homes or replace damaged and lost property. While the percentage of the population that is above 65 years and older is lower for Wayne County (12.7 percent) than for the State of Michigan (13.8 percent) and the United States (13 percent), some of the impacted areas are home to disproportionate numbers of elderly residents. The Long-Term Recovery Group that has formed in response to the flooding has also reported that approximately half of the impacted residents they encounter are elderly. Wayne County also has a higher share of individuals with disabilities (16.1 percent) than the State of Michigan (14.3 percent) and the United States (12.6 percent). ‘These factors further contribute to the inability of the affected population to effectively recover from this disaster. 2Population [Age 65+] Age [Unemployed [Persons Median | Per 9 In witha |Household | Capita _ Poverty [Disability Income __| Income ws. 308,745,538 [18.0% 6.0% 14.6% _|12.6% _|367,652 | $31,177 [Michigan 19,883,640 [13.8% 4% 15.6% |14.3% [$52,668 | $28,938 Wayne [1,820,584 [12.7% 116% 23.7% (16.1% |$43,702 | $24,847 Count D: Population, Age: US. Census Bureau 2010 US. Census Summary File 1 Poverty Level, Income, Unemployment: U.S. Census Bureau American Community Survey 2013-2017 five: year average ‘Median Household Income: U.S, Consus Bureau American Community Survey 2013-2017 five-year average ‘As discussed in the initial request letter, approximately half of the affected population is also vulnerable to racial or ethnic inequities, and subsections of the disaster area include some areas that have disproportionate numbers of non-English speakers, and very young children under the age of five. These socioeconomic conditions exacerbate flood impacts and are an important reason why this disaster requires resources beyond what is available at the local and state levels. Voluntary Agency Assistance In addition to the actions of Voluntary Organizations Active in Disaster (VOADs) outlined in the initial request letter, a local Long-Term Recovery Group has formed to support the recovery of individuals and households. The group is comprised of organizations such as the American Red Cross, United Methodist Committee on Relief (UMCOR), and the Presbytery of Detroit, and has been supported by out-of-state volunteers from World Renew in Wisconsin. The group has registered over 420 cases of households requiring recovery assistance, Needs for assistance range from mucking out and cleaning basements, debris removal, and the structural rebuilding of homes, to the repair of sewer lines on private property. Due to the varied nature of these needs, it is a challenge to identify and target specific organizations that could assist. However, the major difficulty for the Long-Term Recovery Group is to identify sources of funding for recovery activities. So far, only one organization (UMCOR) has contributed significant funds to the budget of the group. In addition to these challenges, many voluntary organizations active in disaster (VOADs) are starting to prepare for the 2019 Hurricane season, which makes it less likely that out- of-state and in-state organizations will deploy resources to support flood recovery in Wayne County in the coming months. ‘The outstanding needs typically addressed by voluntary agencies could most appropriately be met through several federal IA programs. Insurance Per the Preliminary Damage Assessment, only 17.5 percent of affected residents have flood insurance, and 26.4 pereent have water and sewer back-up insurance riders. Therefore, the majority of disaster survivors do not have insurance that covers the damages frequently incurred in this disaster (Le., structural damage to walls and foundations, damage to electrical and mechanical systems, damage to home furnishings, wall treatments, flooring,oss of appliances, and loss of other personal property). The lack of insurance coverage in an area with low household incomes may force residents to occupy homes that are in unsafe conditions. Based on these factors, I maintain that this incident is of such severity and magnitude that effective recovery is beyond the capabilities of the State of Michigan and the affected local jurisdictions. Supplemental federal assistance and activation of IA programs is critically necessary. Captain Emmitt MeGowan of the Michigan State Police, Emergency Management and Homeland Security Division, continues to be the State Coordinating Officer for this request. He will work with FEMA on program implementation and provide further information or justification on my behalf, as requested. Sincerely, Governor