Alone in the Storm: Trump's Plans to Dismantle Federal Disaster Response Will Leave Vulnerable States Behind the Federal Preparedness and Response Elimination Agenda

Alone in the Storm: Trump’s Plans to Dismantle Federal Disaster Response Will Leave Vulnerable States Behind the Federal Preparedness and Response Elimination Agenda

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Ella Helmuth*

Introduction

On June 10, 2025, President Trump informed the press and the country that after the 2025 hurricane season, he and Homeland Security Secretary Kristy Noem plan to dismantle the Federal Emergency Management Agency (FEMA).[1] The President has shared plans to cut funding for disaster aid in general, which will come directly from the President’s office going forward.[2] Consequently, this will drastically change the landscape of emergency response and preparedness in this country.

These plans, and those detailed below, reflect President Trump’s broader aims to limit government spending on the priorities he sees as wasteful;[3] responsibilities for natural and other widespread disasters will shift onto the states. Waiting until after the 2025 hurricane season is a new timeline but not a new plan. President Trump has previously stated: “I say you don't need FEMA, you need a good state government” and called FEMA “not good.”[4] He has cut significant leadership staff from FEMA and others have left.[5] Public and individual aid is already tapering out.[6]

In January of 2025, the White House established a FEMA review council, asserting that federal response to Hurricane Helene and other disasters demonstrated a failure in FEMA’s response capabilities and implicated bureaucratic barriers to successful disaster response.[7] The review council will provide the administration and the agency with recommendations on federal disaster response. At least in part, the establishment of the review council has led the new acting administrator of FEMA, Daniel Richardson, to neglect to publish a hurricane response plan for the 2025 season, which began on June 1.[8] He does not want to “get ahead of” the review council’s recommendations.[9] Trump has taken issue with FEMA in the past over alleged political biases in the agency’s aid responses. This concern is referenced in the order establishing the review council.[10] The council has already begun soliciting feedback from individuals and organizations who have interacted with FEMA in the past.[11]

On March 18, 2025, the Trump administration released Executive Order (EO) 14,239, “ACHIEVING EFFICIENCY THROUGH STATE AND LOCAL PREPAREDNESS.”[12] The Order focuses on the role of state and local governments in disaster resiliency, preparedness, and response.[13] The EO states, “[i]t is the policy of the United States that State and local governments and individuals play a more active and significant role in national resilience and preparedness” and that preparedness is most effectively managed at state, local, and individual levels.[14] It is the position of the EO that transferring more of these responsibilities to the state will save American lives and reduce taxpayer burdens.[15] The EO also asserts that national critical infrastructure resilience policies will shift from the all-hazards approach to a risk-based approach to disaster planning, a drastic departure from traditional models that will be explored later in this article.[16]

In April 2025, the Administration also terminated the Building Resilient Infrastructure and Communities (BRIC) grant program, FEMA’s primary disaster mitigation support for states.[17] BRIC grants supported projects to mitigate risk from future disasters.[18] Communities were required to prove the projects were cost effective and would increase their resilience to such events.[19] The termination of BRIC, in concert with EO 14,239, makes clear that states are not only losing the support of the presidential administration for their preparedness, but their funding for that purpose as well.

The combination of EO 14,239 and the elimination of BRIC, Trump’s stated plans to eliminate FEMA and dismantle its response capabilities, and the broader administrative goal of reducing federal spending has made clear what states may be able to expect in the wake of disasters going forward. FEMA recently denied the provision of aid for Arkansas tornadoes, West Virginia flooding, and Washington windstorms for which officials were anticipating assistance.[20] These denials were seen by state officials as very unusual.[21] In the aftermath of those disasters, a spokesman for the National Security Council, and thus the federal emergency apparatus, said state and local governments “often remain an impediment to their own community’s resilience,” and encouraged states to take a larger role in recovery.[22] This kind of communication shift from federal officials is jarring because FEMA has been the centralized authority for major disaster response for decades.[23] Extended relief was also recently terminated for continued impacts of Hurricane Helene in North Carolina.[24] That state is far from recovered, and its leaders too are left at a loss for how to support their citizens.[25]

This analysis considers the multifaceted impacts of dismantling federal response and preparedness infrastructure as it has existed in the past, with specific analysis of the vulnerabilities created for the state of Kentucky and other high-disaster, under-resourced states. We face the reality of state capacity limitations, the fundamental flaw in the Trump Administration’s plan to turn over disaster management to the states. Second, we explore the new risk-based approach to disaster management and examine how problems with federal emergency response and preparedness have been misinterpreted as structural issues when they are actually failures of implementation. Finally, we consider the particular vulnerabilities for the state of Kentucky caused by the proposed cuts to federal disaster intervention.

EO 14,239, along with President Trump and other officials’ statements, asserts a mandate on state governments to take over their own disaster preparedness and response with limited federal support.[26] This is a misguided upheaval of a system that allows federal disaster management on a scale that could never be achieved in all fifty states, all of which, in the age of climate change, are now at higher risk than ever for major disasters.

I.               The Reality of State Capacity vs Administration Assumptions

Natural disasters in the United States are increasing in frequency and getting more expensive.[27] The United States experienced twenty-seven-billion-dollar disasters in 2024, second only to twenty-eight in 2023.[28] In this context, now is the time to ramp up federal preparedness and response measures while supporting state mitigation efforts, not depend on states with greatly varied capacities to deal with these worsening disasters.

There are major advantages to federal authority over disaster responses, including decades of institutional knowledge, economies of scale, and established systems of communication and authority. Over its history, FEMA has built up expertise and capacity in responding to complex and widespread disasters.[29] The Director of Wyoming’s Office of Homeland Security said, “There are economies of scale [that a nationwide agency provides]. States don't have that capability built to handle a disaster every single year.”[30] To exemplify these economies of scale, Andy Beshear, Governor of Kentucky, explained that the overhead costs of setting up a system at the state level capable of replicating federal disaster response would “eat up most of that money” (the federal money) distributed between all fifty states.[31]  Former FEMA leader Michael Coen said of response and mitigation measures, “Having that capability in every single state instead of having one FEMA is not the best use of tax dollars . . . .”[32] Federal investment in and management of disaster mitigation projects nationwide are essential to ensure efficient use of funds and effort. A study showed that every dollar invested in disaster mitigation by select federal agencies saves six dollars.[33]

In contrast, putting these responsibilities onto each state willfully discards decades of institutional knowledge, the efficiency of operating on a federal scale, and the expertise and resources that come with the federal workforce. States would need “thousands of additional personnel to inspect damage, distribute disaster aid and plan the rebuilding of public infrastructure.”[34] This kind of agency construction also lacks decades of institutional knowledge held by federal agencies and puts states on a serious learning curve. The potential problem is nationwide, but it becomes more urgent in considering smaller states with small budgets, where disasters still threaten serious damage. For example, West Virginia falls in the lower half of state budgets, meaning its staff and resources are limited, but has been hit with severe flooding twice in the last year.[35] A state like West Virginia attempting to build up a program capable of replicating FEMA’s response to such disasters, even with plenty of funding, would be catastrophic if not impossible.

While there are many problems with current federal response and current federal mitigation projects, the answer is not to turn these responsibilities onto the states. Federal agency response can be fragmented and inefficient, but the solution to that problem is not to further fragment response and preparation by dividing it into fifty parts.

The nation has a cooperative aid system called the Emergency Management Assistance Compact, ratified by Congress, which allows states and territories to share resources and personnel in the event of disasters.[36] This kind of coordination from the federal organization prevents competition between states over resources, including personnel. Rescinding federal management would create a situation in which states are rivals for limited resources. This would put under-resourced states like Kentucky and West Virginia at risk of being outbid by states with more competitive economies, creating a potentially dangerous and disparate system of disaster resource distribution. If all the best emergency management staff are drawn to California, smaller states would be left treading water, literally.

II.             Misdiagnosing the Problem: Lessons Learned from Hurricane Katrina

The existing structure of emergency response and preparedness in the United States places FEMA, and its comprehensive “all-hazards” approach to disasters at the forefront.[37] An “all-hazards” approach to emergency management focuses on flexible protocols that can be applied to a broad range of disasters and emergencies.[38] President Trump’s EO and policy statements would shift that approach to a risk-based protocol, a more tailored risk versus benefit strategy which would place responsibility on the states rather than FEMA.[39] The Executive Order explicitly states:

This order empowers State, local, and individual preparedness and injects common sense into infrastructure prioritization and strategic investments through risk-informed decisions that make our infrastructure, communities, and economy resilient to global and dynamic threats and hazards.[40] 

Unfortunately, what the administration sees as common sense is not universal. FEMA’s current “all-hazards” approach, when functioning correctly, allows coordination with state and local governments while ensuring that communities are prepared to respond to a wide variety of potential disasters.[41] As with any system applied to dire situations over a significant period of time, there have been both successes and failures under the “all-hazards” system (see Hurricane Katrina[42] for failure, Hurricane Sandy[43] for success). Given this time of increased and unprecedented natural disasters[44] due to climate change, changing our approach to risk-based seems reckless. Our old risks are no longer indicative of our new ones. The implementation of all-hazards can be improved, but it and the states should not be abandoned. Now is the time to be prepared for anything.

Hurricane Katrina provides evidence for maintaining federal authority and capacity in disaster response in two different ways. The existing “all-hazards” structure was fundamentally sound, but the existing tools and authorities were not properly implemented. Additionally, the federal government was not proactive enough about “pushing” resources to the states. Trump’s plan ensures that the federal government will never be sufficiently proactive by dismantling much of its ability to respond at all.

The White House report following Hurricane Katrina identified a critical flaw in response which required reform:

Our decades-old system, built on the precepts of federalism, has been based on a model whereby local and State governments wait to reach their limits and exhaust their resources before requesting Federal assistance . . . . In other words, the system was biased toward requests and the concept of “pull” rather than toward anticipatory reactions and the proactive “push” of Federal resources.[45]

The problem with federal disaster management during Hurricane Katrina was not the “all-hazards” structure itself, but rather the implementation of existing authorities and protocols. As David Feinberg noted in his argument for greater federal involvement in disaster response, much of the issue with the response to Hurricane Katrina was the slow reaction on the part of every level of government under the cooperative federalist structure.[46] The local government of New Orleans failed to call an evacuation order quickly enough to protect its citizens, the state government failed to request federal assistance in a timely manner, and the federal government did not respond to that request promptly.[47]

However, the tools for an effective response to that disaster already existed within the federal framework. In her article Katrina and the Rhetoric of Federalism, Christina Wells details how the “pull” system collapsed, but shows the fail safes for that in the existing structure of response.[48] The Catastrophic Incident Annex is part of the existing federal system that creates a proactive, overarching federal response to catastrophic disasters by allowing the President to act without a request from the governor.[49] Its use was completely justified during Hurricane Katrina, in fact it was “written for a disaster such as Katrina.”[50] It was never deployed in 2005.[51] This demonstrates that the problem was not structural inadequacy but rather the failure to properly implement existing authorities.

Catastrophes on the scale of Hurricane Katrina require a uniquely proactive federal posture compared to the disasters many states handle every year. This is not because the cooperative federalism, “all-hazards” system in place is wrong, but because the federal government has to take on different roles under different circumstances. “All-hazards” allows this type of flexibility when applied correctly. The effective application of response capabilities under catastrophic circumstances requires the federal government to use their broad authority to the fullest extent. Leaving Louisiana and Mississippi to fend for themselves during Hurricane Katrina would have created an even greater catastrophe than the unprecedented one that occurred. But it is certain that the federal government could have invoked their existing authority and better served their citizens.

Trump’s proposals would reduce federal readiness in the event of a disaster like Katrina. Executive Order No. 14,239 focuses on preparedness and the Administration plans to dismantle the response framework as it exists by abandoning the “all-hazards” approach in exchange for a risk-based approached.[52] This is a departure from the building blocks of decades of emergency preparedness and response, at the federal level and on down. The White House report shows that the government failures of Hurricane Katrina were caused, at least in part, by the lack of federal proactiveness and too much reliance on the state to act before pulling federal resources. The Trump Administration seems intent on solving this problem by creating significantly more barriers to pulling those essential resources.

This fundamental misdiagnosis of the problem with disaster management in this country as one of structurally too much federal power will create inefficiencies and discrepancies that leave states like Kentucky vulnerable to disasters. The “all-hazards” approach provides the necessary flexibility for an era of climate-driven uncertainty, while the post-Katrina analyses pointed toward greater application of federal authority (push, not pull) in a catastrophe. Abandoning both lessons simultaneously represents a dangerous step backward in national disaster preparedness.

III.           Kentucky’s Vulnerability

Shifting the structure of emergency preparedness and response away from federal agencies will have major detrimental impacts on the Commonwealth of Kentucky and other resource-constrained, high disaster occurrence states. Kentucky has received $2.9 billion in federal disaster aid since 2017.[53] In comparison, in the 2024 budget session, the Kentucky legislature implemented caps on disaster spending, allowing the Kentucky Department of Military Affairs to request up to $75 million in the 2024 fiscal year and $100 million total over the 2024 and 2025 fiscal years.[54] It is clear from the disparity in these numbers that Kentucky agencies do not currently possess the capacity to manage billions of dollars in disaster money, the expertise the federal government brings, or the benefit of the economies of scale that exist in federal disaster response. These problems occur even if the federal government pulls their direct physical assistance and distributes financial aid directly to the states, which President Trump’s statements indicate they do not plan to do.

Kentucky has received fifteen major disaster declarations since 2020 and is representative of other resource-constrained states facing a high frequency of disasters.[55] The state’s existing emergency response system has been completely overwhelmed by the frequency of disasters, as Kentucky houses eight of the nine counties in the country with the highest disaster declarations.[56] They have no capacity to do much of anything but triage, much less completely restructure to receive fewer resources from the federal government.[57]

In the year following the 2022 Eastern Kentucky floods, the federal government spent $281 million on Eastern Kentucky recovery.[58] $108 million of that went to individual assistance for flood survivors, and $49.4 million went to public assistance for infrastructure needs.[59] As referenced above, Governor Beshear explained that the overhead costs and staffing needs would be overwhelming.[60] It is simply infeasible to expect states like Kentucky to rebuild efficient disaster preparedness and response mechanisms when the federal government has been managing all fifty states from a gigantic, heavily resourced agency for the past fifty years.

Neither state nor the federal government’s response to the 2022 flooding in Eastern Kentucky, Southwestern Virginia, and West Virginia were perfect. It shone a light on issues with the National Flood Insurance Program, FEMA flood mapping, and emergency alert systems combined with lack of broadband in rural areas.[61] But the flooding did provide an excellent example of what makes state and federal coordination so important in the wake of such a devastating disaster. In many cases, we saw rapid federal response to the flooding. President Biden issued a major disaster declaration covering thirteen counties on July 29, 2022, about two days after flooding began.[62] Temporary federal housing was up in a little more than a month, providing a critical resource for the multitudes of displaced people in the state.[63] This process generally takes several months.[64] There were also federal responses that the state of Kentucky would struggle to replicate. These included interagency recovery coordination from multiple federal agencies, the removal of 409,000 tons of debris from 606 miles of creeks and streams, and a property acquisition program moving the fastest in FEMA history.[65] Kentucky and most other states would be far out of their depth in managing a response of this magnitude.

Conclusion

The Trump Administration’s plan to eliminate federal support for disaster preparedness and response, leaving these essential government functions up to the states, demonstrates a deep misunderstanding of the problems with disaster management in this country. Dismantling decades of federal action and authority will both create financial and structural inefficiencies the administration claims it wants to avoid and leave many states completely vulnerable to disasters they are without the capacity to handle. The system of cooperative federalism as it exists has mechanisms in place to take advantage of economies of scale, allow cooperation between states, and ensure the federal government is a safeguard against state and local failures. The problems of the past are of implementation, not the structure of the system. To improve efficiency and protect citizens, the administration needs to optimize the existing systems, not fragment them into fifty uncoordinated state level parts.

* Member of the Kentucky Bar; J.D. 2024, Georgetown University Law Center; BA English and BA History, Tulane University. I would like to thank my supervisors at Appalachian Citizens' Law Center, who have been supportive of my work for many years. Finally, I would like to publish this piece in memory of my grandfather, Michael Dale Johnson J.D. He was saved from his own home as a small child during flooding in Eastern Kentucky, and fiercely supported my legal education being put to use in service of our communities. He would be proud.

[1] Gabe Cohen, Trump Says He Plans to Phase Out FEMA After 2025 Hurricane Season, CNN (June 11, 2025, 9:11 PM), https://www.cnn.com/2025/06/11/politics/fema-hurricane-season-phase-out-trump [https://perma.cc/23SV-UHPX].

[2] Id.

[3] Exec. Order No. 14,239, 90 Fed. Reg. 13267 (Mar. 18, 2025).

[4] Natalie Daher, Trump’s FEMA Risks “Flying Blind” Into Hurricane Season, Axios (May 21, 2025), https://www.axios.com/2025/05/21/trump-fema-hurricane-season-disasters [https://perma.cc/A2TP-6TRK]; Ella Nilsen, Everyone Agrees FEMA Needs to Change. The Question is How, CNN (Jan. 25, 2025 4:01 AM), https://www.cnn.com/2025/01/25/climate/trump-fema-overhaul [https://perma.cc/6QFU-P264].

[5] Cohen, supra note 1.

[6] Galen Bacharier, FEMA Will Stop Matching 100% of Helene Recovery Money in North Carolina, NC Newsline (Apr. 12, 2025, 7:00 AM), https://ncnewsline.com/2025/04/12/fema-will-stop-matching-100-of-helene-recovery-money-in-nc-stein-says/ [https://perma.cc/5P77-RMYS].

[7] Exec. Order No. 14,180, 90 Fed. Reg. 8743 (Jan. 24, 2025).

[8] Gabe Cohen, FEMA Head Told Staff He Was Previously Unaware US Has a Hurricane Season, CNN (June 3, 2025, 12:08 AM), https://www.cnn.com/2025/06/02/politics/david-richardson-fema-head-unaware-hurricane-season [https://perma.cc/5SS5-U7X6].

[9] Id.

[10] Notice of the Establishment of the Federal Emergency Management Agency Review Council, 90 Fed. Reg. 11, 123 (Feb. 21, 2025).

[11] Request for Public Input on Experiences with FEMA Disaster Responses, 90 Fed. Reg. 13771 (Mar. 26, 2025).

[12] Exec. Order No. 14,239, 90 Fed. Reg. 13267 (Mar. 21, 2025).

[13] Id.

[14] Id.

[15] Id.

[16] Id.

[17]FEMA Ends Wasteful, Politicized Grant Program, Returning Agency to Core Mission of Helping Americans Recovering from Natural Disasters, Fed. Emergency Mgmt. Agency (Apr. 4, 2025), https://www.fema.gov/press-release/20250404/fema-ends-wasteful-politicized-grant-program-returning-agency-core-mission [https://perma.cc/7X7C-QVGW].

[18] FEMA Ends Building Resilient Infrastructure and Communities Program, Am. Soc'y of Civ. Eng’r (Apr. 24, 2025), https://infrastructurereportcard.org/fema-ends-bric-program/ [https://perma.cc/4ZM7-LXRT].

[19] Id.

[20] Arkansas To Appeal Federal Denial for Individual Assistance for March 14 Storm System, Ark. Dep’t Pub. Safety (Apr. 15, 2025), https://dps.arkansas.gov/news/arkansas-to-appeal-federal-denial-for-individual-assistance-for-march-14-storm-system/ [https://perma.cc/TE8W-2ZVW]; Leann Ray, FEMA's Refusal to Help Some West Virginia Counties Just a Taste of What's to Come, W. VA. Watch (Apr. 29, 2025, 5:55 AM), https://westvirginiawatch.com/2025/04/29/femas-refusal-to-help-some-west-virginia-counties-just-a-taste-of-whats-to-come/ [https://perma.cc/KLM8-Q9YE]; Alex Brown, Trump Denies Disaster Aid, Tells States to Do More, Ass’n State Floodplain Managers (May 2, 2025), https://www.floods.org/news-views/fema-news/trump-denies-disaster-aid-tells-states-to-do-more/ [https://perma.cc/4QDR-23Y7].

[21] Brown, supra note 20.

[22] Id.

[23] FEMA: A Comprehensive History of U.S. Emergency Management, EMS1 (Jan. 27, 2025), https://www.ems1.com/emergency-management/fema-a-comprehensive-history-of-u-s-emergency-management [https://perma.cc/3FVR-BHPV].

[24] Bacharier, supra note 6.

[25] See Ben Humphries, Hurricane Helene Recovery Hearing Highlights Delays, Uncertainty in Federal Aid, EDNC (Sept. 25. 2025), https://www.ednc.org/09-25-2025-hurricane-helene-recovery-hearing-highlights-delays-uncertainty-in-federal-aid/#:~:text=As%20the%20recovery%20effort%20continues,it's%20coming%20down%20too%20slowly [https://perma.cc/N93B-2DCW].

[26] Chris Teale, Trump Order Put States at the Forefront of Cyber and Natural Disaster Response, Gov’t Exec. (Mar. 21, 2025), https://www.govexec.com/management/2025/03/trump-order-put-states-forefront-cyber-and-natural-disaster-response/403961/#:~:text=The%20executive%20order%20signed%20this,rather%20than%20the%20federal%20government.&text=President%20Donald%20Trump%20earlier%20this,for%20cybersecurity%2C%20election%20info%20sharing?&text=Could%20states'%20cyber%20get%20trickier%20under%20a%20Trump%20administration? [https://perma.cc/QCA5-CE47].

[27] Adam B. Smith, 2024: An Active Year of U.S. Billion-Dollar Weather and Climate Disasters, NOAA Climate.gov (Jan. 10, 2025), https://www.climate.gov/news-features/blogs/beyond-data/2024-active-year-us-billion-dollar-weather-and-climate-disasters [https://perma.cc/W6EU-CFFN].

[28] Id.

[29] Historic Disasters, Fed. Emergency Mgmt. Agency (Feb. 27, 2025), https://www.fema.gov/disaster/historic [https://perma.cc/G2AW-YFQJ].

[30] Ming Xie, If FEMA Didn't Exist, Could States Handle the Disaster Response Alone?, Univ. Md. Balt. Cnty. (Feb. 10, 2025), https://umbc.edu/stories/if-fema-didnt-exist-could-states-handle-the-disaster-response-alone/ [https://perma.cc/Z9C5-F6GM]; Alex Brown & Kevin Hardy, Trump Wants States to Handle Disasters Without FEMA. They Say They Can’t., Stateline (Feb. 6, 2025), https://stateline.org/2025/02/06/trump-wants-states-to-handle-disasters-without-fema-they-say-they-cant/#:~:text=State%20officials%20say%20that%20while,a%20disaster%20every%20single%20year.%E2%80%9 [https://perma.cc/W3HK-DD39].

[31] McKenna Horsley, Beshear Says Dismantling FEMA Would Be 'Disastrous' Though Improvements Need to Continue, Ky. Lantern (Feb. 6, 2025), https://www.tribunecourier.com/news/beshear-says-dismantling-fema-would-be-disastrous-though-improvements-need-to-continue/article_24a2bbeb-20ed-5f04-a853-858d7c277ef5.html [https://perma.cc/32PF-PZVW].

[32] Brown, supra note 20.

[33] Nat’l Inst. Bldg. Sci., Natural Hazard Mitigation Saves: 2017 Interim Report, at 1 (2017).

[34] Lauren Sommer, Trump Wants States to Handle Disasters. States Aren't Prepared, Nat’l Pub. Radio (Mar. 21, 2025, 4:08 PM), https://www.npr.org/2025/03/21/nx-s1-5327595/trump-order-fema-states-disaster-response [https://perma.cc/V7MJ-3DYG].

[35] Gazette-Mail Editorial: WV Must Do More Better in Prepping for Emergencies, Charleston Gazette Mail (Nov. 12, 2025), https://www.wvgazettemail.com/opinion/editorial/gazette-mail-editorial-wv-must-do-better-in-prepping-for-emergencies/article_17be393c-634c-47fd-a7de-7bf4ef4639aa.html [https://perma.cc/7UD9-QTGQ]; Chapter IV: Government in West Virginia, W.V. Univ: John Chambers Coll. Bus. and Econ., https://business.wvu.edu/research-outreach/bureau-of-business-and-economic-research/economic-outlook-conferences-and-reports/economic-outlook-reports/west-virginia-economic-outlook-2021-2025/chapter-iv-government-in-west-virginia#:~:text=West%20Virginia%20Government,are%20devoted%20to%20government%20expenditures [https://perma.cc/XND7-2Y36].

[36] Emergency Management Assistance Compact, https://www.emacweb.org/ [https://perma.cc/8VX5-5XE5].

[37] See Fed. Emergency Mgmt. Agency, State and Local Guide (SLG) 101: Guide for All-Hazard Emergency Operations Planning 6-1 (1996).

[38] Bruria Adini, Avishay Goldberg, Robert Cohen, Daniel Laor, & Yaron Bar-Dayan, Evidence-Based Support for the All-Hazards Approach to Emergency Preparedness, 1 Isr. J. Health Pol’y Res. no. 40, 2012, at 1, 1.

[39] Nat’l Aeronautics Space Admin., Risk Informed Decision Making 7, 12 (Apr. 2010), https://ntrs.nasa.gov/api/citations/20100021361/downloads/20100021361.pdf [https://perma.cc/8XAR-77GN] (describing risk-based decision making framework); Exec. Order No. 14,239, supra note 3.

[40] Exec. Order No. 14,239, supra note 3, at § 1.

[41] Fed. Emergency Mgmt. Agency, supra note 37 at iii.

[42] See Peter A. Gregory, Reassessing the Effectiveness of All-Hazards Planning in Emergency Management, 7 Inquiries J. Student Pulse, no. 6, 2015, at 1.

[43] Id.

[44] Theo Rosen, There Were 27 Major Climate-Related Disasters in the U.S. in 2024, Env’t Am. (Jan. 7, 2025), https://environmentamerica.org/center/updates/there-were-27-major-climate-related-disasters-in-the-u-s-in-2024/ [https://perma.cc/6ZJC-JSU3].

[45]  Frances Fragos Townsend, The White House, The Federal Response to Hurricane Katrina: Lessons Learned 66 (2006).

[46] David L. Feinberg, Hurricane Katrina and the Public Health-Based Argument for Greater Federal Involvement in Disaster Preparedness and Response, 13 Va. J. Soc. Pol'y & L. 596, 622–24 (2006).

[47] Id. at 609–10.

[48] Christina Wells, Katrina and the Rhetoric of Federalism, 26 Miss. C. L. Rev. 127 (2007).

[49] U.S. Dep’t of Homeland Sec., National Response Plan: Catastrophic Incident Annex (Dec. 2004), https://www.dco.uscg.mil/Portals/9/CG-5R/nsarc/Catastrophic_Incident_Annex.pdf [https://perma.cc/2XFK-6QA9].

[50] Wells, supra note 48, at 140.

[51] Id.

[52] Exec. Order No. 14,239, supra note 3.

[53] McKenna Horsley, Some Kentucky Republicans Echo Trump's Complaints About FEMA After Latest Flood, Ky. Lantern (Feb. 19, 2025, 9:49 AM), https://kentuckylantern.com/2025/02/19/some-kentucky-republicans-echo-trumps-complaints-about-fema-after-latest-flood/ [https://perma.cc/W6QD-E9EX].

[54] Liam Niemeyer, Kentucky Legislature Sends State Budget Bill to Governor, Including Billions in One-Time Spending, Ky. Lantern (Mar. 29, 2024, 1:51 AM), https://kentuckylantern.com/2024/03/29/kentucky-legislature-sends-state-budget-bills-to-governor-including-billions-in-one-time-spending/ [https://perma.cc/6XHW-QF6Y].

[55] Disasters and Other Declarations, Fed. Emergency Mgmt. Agency, https://www.fema.gov/disaster/declarations?field_dv2_declaration_date_value%5Bmin%5D=2020&field_dv2_declaration_date_value%5Bmax%5D=2025&field_dv2_declaration_type_value=DR&field_dv2_incident_type_target_id_selective=All&field_dv2_state_territory_tribal_value%5B0%5D=KY&page=0 [https://perma.cc/R33M-TUTX].

[56] Associated Press, Kentucky and Vermont Top List for Highest Number of Declared Disaster Areas, Spectrum News 1 (July 23, 2024, 11:57 AM), https://spectrumnews1.com/ky/louisville/news/2024/07/23/inland-counties-top-disaster-list [https://perma.cc/Z8CR-K8H9].

[57] Virtual Meeting with Eddie Jacobs, Department of Local Government (Feb. 11, 2025) (on file with author).

[58] Commonwealth and FEMA Flood Recovery on Course One Year Later, Fed. Emergency Mgmt. Agency (Jan. 22, 2025), https://www.fema.gov/press-release/20250122/commonwealth-and-fema-flood-recovery-course-one-year-later [https://perma.cc/4NBE-AC6K].

[59] Id.

[60] Horsley, supra note 31.

[61] Casey Tolan, 'We Thought We Were Safe': Kentucky Disaster Shows How US Is Ill-Prepared and Under-Insured for Devastating Floods, CNN (Aug. 15, 2022, 7:38 AM), https://www.cnn.com/2022/08/15/us/fema-kentucky-flood-insurance-climate-change-invs/index.html [https://perma.cc/F4UE-QMZU]; Claire Carlson & Anya Petrone Slepyan, In the Face of Extreme Flooding, Rural Kentucky Lacked Forecasting and Broadband, Daily Yonder (Mar. 23, 2023), https://dailyyonder.com/rural-kentucky-floods-lack-of-forecasting-broadband/2023/03/23/ [https://perma.cc/HEW3-KSCL].

[62] DR-4663-KY Initial Notice, Fed. Emergency Mgmt. Agency (July 29, 2022), https://www.fema.gov/disaster-federal-register-notice/dr-4663-ky-initial-notice [https://perma.cc/VCD2-VLA6].

[63] Six Months and $154.6 Million Later, Eastern Kentucky Recovery Continues, Fed. Emergency Mgmt. Agency (Jan. 27, 2023) https://www.fema.gov/press-release/20250121/six-months-and-1546-million-later-eastern-kentucky-recovery-continues [https://perma.cc/CB4Z-6JMW].

[64] Id.

[65] Commonwealth and FEMA Flood Recovery on Course One Year Later, supra note 53; Six Months and $154.6 Million Later, Eastern Kentucky Recovery Continues, supra note 59.