Connecticut’s two U.S. Senators and two of its members of the House of Representatives Wednesday asked Federal Emergency Management Agency Director David Paulison to reevaluate the agency’s denial of disaster assistance for Waterbury, Conn.
Senators Chris Dodd, D-Conn., and Joe Lieberman, D-Conn., and Representatives Nancy Johnson, R-Conn., and Rosa Delauro, D-Conn. – in a letter to Paulison dated October 23, 2006 – pointed out that the city had provided additional documentation regarding damage to the city following a severe storm June 2, 2006. Furthermore, the four Members of Congress, all of whom represent Waterbury, argued that FEMA’s own regulations appear to warrant disaster assistance to the city.
“The June 2 storm had a devastating financial impact on the City of Waterbury – damaging critical facilities including its sewage system and aspects of its transportation system,” the letter said. “The declaration is supported under FEMAS’s regulations and we strongly support Governor Rell’s request…”
Following is full text of the letter:
October 25, 2006
The Honorable R. David Paulison
Federal Emergency Management Agency
500 C Street, S.W.
Washington, DC 20472
Dear Director Paulison:
We are writing in support of Governor Rell’s appeal of FEMA’s rejection of her July 27, 2006 request for a major disaster declaration. FEMA denied the State of Connecticut’s request for a major disaster declaration for severe damage, particularly to the City of Waterbury, from heavy rains and flash flooding on June 2, 2006.
Since Governor Rell initially sought the declaration, the State of Connecticut and the City of Waterbury have obtained additional evidence detailing the storm damage, and in her appeal Governor Rell has requested a new inspection of the damages. Some of this evidence includes additional documentation regarding damage to the City of Waterbury’s sewage system and bids the City of Waterbury has obtained for repairing storm damage. We support Governor Rell’s request for a new inspection which we believe will support the City of Waterbury’s total damages more accurately.
In addition, despite FEMA’s initial denial decision, a disaster declaration appears to be warranted under its own regulations. FEMA’s staff stated that Connecticut’s request for a declaration was denied because the eligible damages did not reach the statewide or countywide threshold for damages. However, although FEMA’s public assistance disaster aid regulations require an evaluation of statewide damages, where the statewide threshold is not met, FEMA must evaluate the localized impacts of the damages. 44 CFR 206.48. Specifically, the regulations state that FEMA will:
…evaluate the impact of the disaster at the county and local government level . . . because at times there are extraordinary concentrations of damages that might warrant Federal assistance even if the statewide per capita is not met. This is particularly true where critical facilities are involved or where localized per capita impacts might be extremely high. For example, we have at times seen localized damages in the tens or even hundreds of dollars per capita though the statewide per capita impact was low.
44 CFR 206.48(a)(2) (emphasis added).
Although Connecticut has “county” boundaries, these boundaries lack any real or legal significance because, as recognized by the U.S. Census Bureau in its Government Finance and Employment Classification Manual, Connecticut has no “county government.” Because Connecticut has no “county government,” FEMA must look at the impact of the disaster at the “local government” level. In this instance, the City of Waterbury bears the burden of the damages from the flooding because there is no “county government” to help absorb the repair costs. Thus, the relevant factor is the per capita damages per Waterbury resident, not per New Haven County resident.