Some Ramifications of Project 2025 for Disabled People During Disasters

The Partnership for Inclusive Disaster Strategies (The Partnership) is the only U.S. disability-led organization with a focused mission of equity for people with disabilities and people with access and functional needs throughout all planning, programs, services and procedures before, during and after disasters and emergencies.

We achieve our mission through:

  • Disability-led disaster response and community resilience
  • Community engagement, organizing and leadership development
  • Advocacy and systems change
  • Training, technical assistance and research
  • Unwavering support for local disability organizations

The Partnership prioritizes equity, access, disability rights, disability justice, and full inclusion of people with disabilities, older adults, and people with access and functional needs before, during and after disasters and emergencies. We recognize that prevention, planning, response, recovery and mitigation must start with and be led by multiply marginalized disabled people who are the most disproportionately impacted.

We envision whole community readiness, support when disaster strikes, and disability inclusive engagement throughout disaster preparedness, mitigation, response and recovery to build back better, optimize community resilience, and improve disaster outcomes for all.

The Partnership’s mission is made more imperative by the fact that disabled people are already 2-4 times more likely to die or be injured in disasters than non-disabled people. Disasters have an even greater impact  on disabled people with multiple marginalized identities, including disabled people of color and disabled people experiencing houselessness.

Project 2025 is organized by the Heritage Foundation with support from over 100 other organizations. Although described as a presidential transition plan, it has not been endorsed by any major presidential candidate. Should the ideas proposed in Project 2025 be adopted, they would threaten The Partnership’s ability to fulfill its mission.

In order to be treated equitably in disasters disabled people need support from the federal government. People with disabilities are reliant on a robust federal government that can quickly and equitably provide services to disabled people in disasters. Cuts and other changes posed in Project 2025 would weaken, and in some cases dismantle, federal agencies that are already struggling to adequately support disabled disaster survivors. 

The paragraphs below list agencies who would be changed by policies proposed in Project 2025, the function of the agency, and the ramifications these changes may have for disabled people. All of these potential changes would directly impede The Partnership’s ability to ensure equity during disasters, including public health emergencies.

 

Federal Agency: Federal Emergency Management Agency (FEMA)

Agency’s purpose:

FEMA is headquartered in Washington, D.C., and has 10 regional offices across the country. It leverage[s] a tremendous capacity to coordinate within the federal government to make sure America is equipped to prepare for and respond to disasters.”

FEMA plays a major role in providing state, territorial, and tribal governments support after a federal disaster has been declared. It has obligations to do this in a way that does not discriminate against disabled people.

Some Project 2025 recommendations regarding FEMA:

p.134

“The Federal Emergency Management Agency (FEMA) be moved to the Department of the Interior or, if combined with CISA, to the Department of Transportation.”

Ramifications for Disabled people: There is risk that FEMA’s purpose and functions will become marginalized and under-resourced as a result of being moved. Like other cuts to FEMA’s capacity, this will result in fewer resources for disabled people. This in turn will result in poorer outcomes for disabled people including increased rates of injury, illness, institutionalization, and premature death.

p.153 

“Under the Stafford Act, FEMA has the authority to adjust the per capita indicator for  damages, which creates a threshold under which states and localities are not eligible for public assistance. FEMA should raise the threshold because the per capita indicator has not kept pace with inflation, and this over time has effectively lowered the threshold for public assistance and caused FEMA’s resources to be stretched perilously thin.”

“Alternatively, applying a deductible could accomplish a similar outcome while also incentivizing states to take a more proactive role in their own preparedness and response capabilities. In addition, Congress should change the cost-share arrangement so that the federal government covers 25 percent of the costs for small disasters with the cost share reaching a maximum of 75 percent for truly catastrophic disasters.”

Ramifications for Disabled people: These proposed changes will to varying degrees, shift the responsibilities from the federal government for supporting households and communities in recovery from disasters to states and territories. Given that a federal disaster declaration can only be issued when the demand for resources has exceeded states’/territories’ capacity, the proposed changes will result in there being fewer resources for disabled people after disasters.

p.153-4

“FEMA is also responsible for the National Flood Insurance Program (NFIP), nearly all of which is issued by the federal government. Washington provides insurance at prices lower than the actuarially fair rate, thereby subsidizing flood insurance. Then, when flood costs exceed NFIP’s revenue, FEMA seeks taxpayer-funded bailouts. Current NFIP debt is $20.5 billion, and in 2017, Congress canceled $16 billion in debt when FEMA reached its borrowing authority limit. These subsidies and bailouts only encourage more development in flood zones, increasing the potential losses to both NFIP and the taxpayer. The NFIP should be wound down and replaced with private insurance starting with the least risky areas currently identified by the program.”

Ramifications for Disabled people: Private insurance will be prohibitively costly and fewer households  will have flood insurance. This will make the community less resilient. When communities are made less resilient, marginalized communities, including households of disabled people will be disproportionately affected. As is always the case, disabled people with intersectional identities will be most impacted.  

p.154

“FEMA manages all grants for DHS [Department of Homeland Security], and these grants have become pork for states, localities, and special-interest groups. Since 2002, DHS/FEMA have provided more than $56 billion in preparedness grants for state, local, tribal, and territorial governments. For FY 2023, President Biden requested more than $3.5 billion for federal assistance grants.13 funds provided under these programs do not provide measurable gains for preparedness or resiliency. Rather, more than any objective needs, political interests appear to direct the flow of non-disaster funds.

The principles of federalism should be upheld; these indicate that states better understand their unique needs and should bear the costs of their particularized programs. FEMA employees in Washington, D.C., should not determine how billions of federal tax dollars should be awarded to train local law enforcement officers in Texas, harden cybersecurity infrastructure in Utah, or supplement migrant shelters in Arizona. DHS should not be in the business of handing out federal tax dollars: These grants should be terminated.”

Ramifications for Disabled people: Many preparedness grants have been used to ensure that emergency management practices are inclusive of the needs of disabled people. This includes funding to ensure emergency/disaster shelters are accessible and disability inclusive, for the creation and dissemination of accessible information, and for auxiliary aids and services such as sign language interpreters, Communication Access Realtime Translation (CART), and materials in Braille or alternate formats.

Even though it has not been substantiated that “programs do not provide measurable gains for preparedness or resiliency,” government entities, NGOs and others will not have the opportunity to learn what is required of them under the law regarding providing access to disabled people and will not have the opportunity to learn how to best meet the needs of disabled people. Government entities and NGOs will no longer have the opportunity to share practices for supporting disabled people in preparing for disasters and Disabled people will not have the opportunity to learn how to best prepare for disasters.

Removing sources of federal funding, will weaken federal civil rights protection under section 504 of the Rehabilitation Act by depleting enforcement resources.

 

Federal Agency: Department of Homeland Security, Office For Civil Rights and Civil Liberties (CRCL)

Agency’s purpose:

“The Office for Civil Rights and Civil Liberties (CRCL)” is an office within the Department of Homeland Security and “supports the Department [of Homeland Security’s] mission to secure the nation while preserving individual liberty, fairness, and equality under the law. CRCL builds in civil rights and civil liberties practices into all of the Department’s activities by:

  • Promoting respect for civil rights and civil liberties in policy development and implementation by advising Department leadership and personnel, and state and local partners.
  • Communicating with individuals and communities whose civil rights and civil liberties may be affected by Department activities, informing them about policies and avenues of remedy, and promoting appropriate attention within the Department to their experiences and concerns.
  • Investigating civil rights and civil liberties complaints filed by the public regarding Department policies or activities, or actions taken by Department personnel.
  • Leading the Department's equal employment opportunity programs and promoting workforce diversity and merit system principles.”

Project 2025 recommendations for the Office of Civil Rights and Civil Liberties:

p.164

“The Homeland Security Act established only an Officer of CRCL, not an office. The only substantive function Congress then assigned to the officer was to review and assess information alleging abuses of civil rights. Since then, Congress and CRCL itself have significantly expanded CRCL’s scope and size well beyond its original intent or helpful purpose. CRCL now operates and views itself as a quasi- DHS Office of Inspector General. This results in a considerable waste of limited component resources, which are routinely tasked to address redundant, overly burdensome, and uninformed demands from CRCL. It is therefore important to recalibrate CRCL’s scope and reach.

The organizational structure of both CRCL and the Privacy Office [PRIV] should be changed to ensure proper alignment with the department’s mission. The Office of General Counsel should absorb both CRCL’s and PRIV’s necessary functions”

Ramifications for Disabled people: Monitoring and enforcement of the civil rights of disabled people have never been adequately resourced by the federal government. This change would render CRCL unable to contribute to meaningful monitoring and enforcement of the rights of disabled people in disasters.

 

Federal Agency: National Oceanic and Atmospheric Administration (NOAA)

Agency’s purpose:

“From daily weather forecasts, severe storm warnings, and climate monitoring to fisheries management, coastal restoration and supporting marine commerce, NOAA’s products and services support economic vitality and affect more than one-third of America’s gross domestic product. NOAA’s dedicated scientists use cutting-edge research and high-tech instrumentation to provide citizens, planners, emergency managers and other decision makers with reliable information they need, when they need it.

NOAA’s mission to better understand our natural world and help protect its precious resources extends beyond national borders to monitor global weather and climate, and work with partners around the world. 

Our agency holds key leadership roles in shaping international ocean, fisheries, climate, space and weather policies. NOAA’s many assets — including research programs, vessels, satellites, science centers, laboratories and a vast pool of distinguished scientists and experts — are essential, internationally recognized resources. We work closely with other nations to advance our ability to predict and respond to changes in climate and other environmental challenges that imperil Earth’s natural resources, human life and economic vitality.”

Project 2025 recommendations for the National Oceanographic and Atmospheric Administration:

p.664

“The National Oceanographic and Atmospheric Administration (NOAA) should be dismantled and many of its functions eliminated, sent to other agencies, privatized, or placed under the control of states and territories.”

Ramifications for Disabled people: At a time when climate change is fueling more frequent and severe disasters, it is particularly ill advised to dismantle NOAA. This is a time when the federal government should be devoting more resources to NOAA, not dismantling it. Dismantling NOAA will likely result in increased injury and death, disproportionately impacting disabled people. 

p.675-676

“Review the Work of the National Hurricane Center and the National Environmental Satellite Service. The National Hurricane Center and National Environmental Satellite Service data centers provide important public safety and business functions as well as academic functions, and are used by forecasting agencies and scientists internationally. Data continuity is an important issue in climate science. Data collected by the department should be presented neutrally, without adjustments intended to support any one side in the climate debate.”

Ramifications for Disabled people: It is dangerous for everyone, and particularly for disabled people when established science is relegated to an issue that is debatable, people will become ill, be injured, and die earlier. Again, the impact will be much greater on disabled people. Lack of accurate up-to-date information about disasters as soon as possible will impede The Partnership's ability to provide accurate, accessible and actionable warnings to disabled people about impending disasters in a timely manner, creating a greater risk to their safety, and the safety of the whole community. 

 

Federal Agency: Centers for Disease Control and Prevention (CDC)

Agency’s purpose:

“The CDC increases the health security of our nation. As the nation's health protection agency, CDC saves lives and protects people from health threats. To accomplish our mission, CDC conducts critical science and provides health information that protects our nation against expensive and dangerous health threats and responds when these arise.”

CDC is a division of the Department of Health and Human Services (HHS).

Project 2025 recommendations for the CDC:

p.452

COVID-19 exposed the Centers for Disease Control and Prevention (CDC) as perhaps the most incompetent and arrogant agency in the federal government. CDC continually misjudged COVID-19, from its lethality, transmissibility, and origins to treatments. We were told masks were not needed; then they were made mandatory. CDC botched the development of COVID tests when they were needed most. When it was too late, we were told to put our lives on hold for “two weeks to flatten the curve;” that turned into two years of interference and restrictions on the smallest details of our lives. Congress should ensure that CDC’s legal authorities are clearly defined and limited to prevent a recurrence of any such arbitrary and vacillating exercise of power.”

Ramifications for Disabled people: Limiting the authority of the CDC could result in injury, institutionalization and premature deaths of disabled people. Discrediting an agency that prevented the deaths of disabled people by anthropomorphizing it and referring it as “arrogant” will not support disabled people in maintaining their health during the very real instances of COVID that continue to occur, or in future pandemics and public health emergencies that may foreseeably have a disproportionate impact on disabled people.

 p.454

“By statute or regulation, CDC guidance must be prohibited from taking on a prescriptive character. For example, never again should CDC officials be allowed to say in their official capacity that school children “should be” masked or vaccinated (through a schedule or otherwise) or prohibited from learning in a school building. Such decisions should be left to parents and medical providers. We have learned that when CDC says what people “should” do, it readily becomes a “must” backed by severe punishments, including criminal penalties. CDC should report on the risks and effectiveness of all infectious disease-mitigation measures dispassionately and leave the “should” and “must” policy calls to politically accountable parties.”

Ramifications for Disabled people: Disabled children will continue to become ill and die at disproportionate rates if the CDC is prohibited from providing critical life-saving guidance or advising that “school children 'should be masked’ or vaccinated (through a schedule or otherwise).“ 

p.283-4

“HHS is also home to the Centers for Disease Control and Prevention (CDC) and the National Institutes of Health (NIH), the duo most responsible …for the irrational, destructive, un-American mask and vaccine mandates that were imposed upon an ostensibly free people during the COVID-19 pandemic. All along, it was clear from randomized controlled trials— the gold standard of medical research—that masks provide little to no benefit in preventing the spread of viruses and might even be counterproductive. Yet the CDC ignored these high-quality RCTs [Randomized controlled trials], cherry-picked from politically malleable “observational studies,” and declared that everyone except children and infants below the age of two should don masks.”

Ramifications for Disabled people: Denying vaccine and mask effectiveness will cause people, particularly disabled people, to contract COVID and Long COVID at disproportionately higher rates. This can result in more severe illness and higher mortality rates among disabled people. Marginalizing the CDC and NIH can also lead to the disproportionate COVID illness and early deaths of disabled people.

 

Federal Agency: Center for Medicare & Medicaid Services (CMS)

Agency’s purpose:

CMS is the federal agency that provides health coverage to more than 160 million people through Medicare, Medicaid, the Children's Health Insurance Program, and the Health Insurance Marketplace. CMS works in partnership with the entire health care community to improve quality, equity, and outcomes in the health care system.”

Project 2025 recommendations regarding CMS

p.475-6

“COVID-19 Vaccination and Mask Requirements. Health care workers were praised for their self-sacrifice in caring for sick patients at the beginning of the COVID-19 pandemic, but then they were fired if they objected to receiving COVID-19 vaccines with or without complying with onerous masking requirements and regardless of whether they already had the virus and had gained natural immunity. With the disease  being endemic and constantly mutating, vaccines and universal masking in health care facilities do not have appreciable benefits in reducing COVID-19 transmission throughout the community. Moreover, more recent COVID strains pose fewer health risks than the earlier strains, and the pandemic has been declared to be at an end. CMS should:

  • Announce nonenforcement of the Biden Administration’s COVID-19 vaccination mandate on Medicaid and Medicare hospitals.
  • Revoke corresponding guidance and regulations.
  • Refrain from imposing general COVID-19 mask mandates on health care facilities or personnel.
  • Pay damages to all medical professionals who were dismissed directly because of the CMS vaccine mandate.”

Ramifications for Disabled people: Since COVID continues to spike and develop new variants, non-enforcement of vaccination mandates and revoking guidance on regulations; and refraining from imposing general mask requirements when warranted will have a negative effect on disabled people who are disproportionately affected by COVID-19. 

The critical work we do at The Partnership is more urgent than ever, particularly in light of emerging threats such as the changes proposed by Project 2025, which would deeply undermine the federal support structures that our communities depend on during disasters. These proposed changes would exacerbate existing barriers and further marginalize disabled people, increasing our risks of injury, institutionalization, and death due to disasters.

Disability rights are human rights! We are committed to leading disability-led inclusive disaster strategies throughout the nation. The Partnership will continue to advocate for  systems change and direct support for local disability-led organizations to ensure that no one, especially the most marginalized among us, is left behind. As always, our work is driven by the people most impacted, and we will continue to fight for a future where disaster preparedness, response, and recovery are fully inclusive and equitable for all.

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