Who is a member?
Our members are the local governments of Massachusetts and their elected and appointed leadership.
Matthew Gorzkowicz, Secretary of the Executive Office for Administration and Finance
℅ Khushbu Webber, Deputy General Counsel, Executive Office for Administration and Finance;
Caroline Elmendorf, Deputy Chief of Staff, Executive Office for Administration and Finance
801 CMR 29.00: Disaster Relief and Resiliency Fund
State House, Boston
Delivered electronically
Dear Secretary Gorzkowicz and the Executive Office for Administration and Finance team,
On behalf of all 351 cities and towns across the Commonwealth, I write today to offer our appreciation and input on 801 CMR 29.00, the regulations governing the new Disaster Relief and Resiliency Fund (DRRF).
First, we are deeply grateful for the creation of the DRRF — the importance of this fund cannot be overstated.
As cities and towns across the Commonwealth continue to navigate compounding fiscal pressures that are straining local resources, our communities need robust support in the aftermath of an emergency.
We offer our heartfelt appreciation to Governor Maura Healey, the Legislature, and the teams at A&F, the Massachusetts Emergency Management Agency, and beyond for implementing this program swiftly and smartly. Thank you for your efforts to stand up a program that will fill critical gaps in disaster relief support.
As you know, in the aftermath of an emergency event, municipalities lead the charge to triage, stabilize, and rebuild. Municipal leaders work closely with neighboring communities, MEMA, and other state departments to tackle the many challenges that arise after such an event, while also diligently following extensive rules and procedures that impact potential federal reimbursements and respect local fiscal limitations.
Our members regularly report on the difficulties and process burdens associated with disaster response and have requested additional, consistent support throughout the response process. This may include assigning an individual case manager to act as a main advisor to communities. This position would help to ensure that processes are completed appropriately from the start, reducing risk of reporting or tracking mistakes and streamlining administrative and coordination efforts.
We applaud A&F’s strategy to base the DRRF processes on existing practices, limiting additional administrative burdens for local officials. We strongly urge you to continue to center this practice of prioritizing ease and efficiency as you refine the program rules.
We appreciate the thoughtful approach to drafting these regulations to include a provision that would allow the Governor authority to engage the fund to respond to unique circumstances. However, in the spirit of reducing executive burden and consideration of all eligible events, we urge you to revise the rules to allow for single municipalities to still engage the fund under qualifying circumstances.
As well, given the dynamic and rapidly changing federal policy landscape, including proposed changes at the Federal Emergency Management Agency (FEMA), we strongly urge you to revise the proposal regarding favorable weight to cities and towns that maintain up-to-date Municipal Vulnerability Preparedness Plans (MVP) and Hazard Mitigation Plans (HMP). While we understand the interest in encouraging vulnerability planning, cities and towns often face a number of circumstances that can contribute to out-of-date plans, in particular, HMP plans. Changes at FEMA, limited financial and human resources in a community, and unexpected impacts on the planning process timeline are just a few barriers that can affect whether or not a community may hold an expired HMP at the time of a qualifying event.
In order to resolve this issue, we suggest engaging one or more of the following solutions:
1. Allow a one-year grace period for plan expirations. As noted, a number of factors can contribute to delays in refreshing a plan. Allowing a one-year grace period following the expiration of a plan would allow adequate buffer time to ensure cities and towns do not miss out on this multiplier.
2. Reduce the requirement for this favorable weight to require either an up-to-date MVP or HMP.
3. De-emphasize the weight given to these plans. The proposal suggests a 25% multiplier to communities with both MVP and HMPs in hand. Reducing this multiplier could help alleviate concerns regarding HMP expirations.
Lastly, we encourage the final rules to explicitly include engineering, design, and permitting as allowable expenses.
We greatly appreciate the work of the A&F team to create a program that will provide essential support to cities and towns for disaster relief. We celebrate the creation of this landmark program and urge the continued growth of this fund as resources are available.
Please do not hesitate to reach out to me or MMA Senior Legislative Analyst Adrienne Núñez at [email protected] at any time. Many thanks for your thoughtful consideration of municipal government input and your continued partnership to ensure communities in all regions of the Commonwealth are well-supported through sunny days and when disaster strikes.
Sincerely,
Adam Chapdelaine
MMA Executive Director and CEO