Bit by bit, President Trump has been chopping away at the Federal Emergency Management Agency (FEMA) downsizing it through cuts to the agency’s staff, programs and mission. Reports last week revealed a daunting threat from Department of Homeland Security (DHS) Secretary Noem, who announced in a cabinet meeting: “We’re going to eliminate FEMA.”
Neither Secretary Noem nor President Trump has the legal authority to abolish FEMA—that power lies with Congress. Furthermore, dismantling or eliminating FEMA will endanger millions of people who rely on the agency to help prepare for and recover from disasters.
In fact, legislators from both parties signaled the need for FEMA by introducing legislation to transform it into a stand-alone, cabinet level agency as it once was before the Department of Homeland Security was formed. Republican Representative Byron Donalds and Democrat Representative Jared Moskowitz, both of Florida, introduced the bill on March 24, 2025.
Days before the DHS Secretary’s statement, on March 19, the president signed an executive order (EO) titled “Achieving Efficiency Through State and Local Preparedness.” This action follows his earlier EO in January establishing a FEMA review council. While sparse on details, this new order prompts a major change in federal policy.
While details are scarce in the EO, there are two clear themes that emerge: shifting the burden of disaster response from the federal government to state and local government—even for major disasters that overwhelm states’ capacities—and using frames like “streamlining” and “efficiency” which this administration is already disingenuously using to decimate agency staffing and budgets to the point that they cannot fulfill their missions. Both of these will create significant risk and harm for communities in the path of and reeling from disasters.
Below I provide a summary of the EO including the new policy, initiatives and updates to current federal policies and the takeaways for each.
1. Shifting the national resilience and preparedness burden to state and local governments
The most significant piece of policy in the executive order seems to simply put in writing what he has been saying he wants all along: to shift more responsibility for disaster resilience, preparedness and response onto the shoulders of state, local, tribal, territorial governments.
If it comes to pass, disaster response and recovery will be more chaotic and ineffective, endangering more lives—especially the elderly, youth, those who have disabilities and others with fewer resources to prepare or evacuate. States, even larger states, don’t have the resources to handle catastrophic disasters. In those cases, governors will ask for a presidentially declared disaster.
Key takeaway: What will change for states?
Effective and well-resourced emergency preparedness and disaster response can mean the difference between life and death. Given that, the lack of details in the executive order (and fact sheet) is baffling, particularly considering the planning, time and level of funding that is needed for disaster preparedness and resilience. States will be unprepared to respond to major disasters on their own. That’s particularly dangerous during the summer months (May-October) when the risks of extreme heat, hurricanes, wildfires and floods tend to peak and collide—a time UCS calls “Danger Season.”
What level of coordinating capabilities, boots on the ground, financial resources and technical expertise can these state and local jurisdictions expect from FEMA when a major disaster is declared? This NPR article speaks to what will be at stake if FEMA is taken out of the equation:
“Without FEMA, states would need to find thousands of additional personnel to inspect damage, distribute disaster aid and plan the rebuilding of public infrastructure. Without federal funding, states would face billions of dollars in recovery costs. After Hurricane Irma in 2017, Florida relied on more than $5.5 billion dollars from the federal government.”
Of course, FEMA also helps with preparedness, as the article points out. And while there is a lot more that Congress and this administration could do to incentivize more emergency readiness by state, local, tribal and territorial governments, this administration hasn’t shown it understands the concept of reducing risk.
2. Develop a national resilience strategy
Section 3 of the executive order calls for a national resilience strategy to be developed within 90 days of the order. Specifically, it calls for the Assistant to the President for National Security Affairs Michael Waltz, in coordination with the Assistant to the President for Economic Policy Kevin Hassett, to develop “a national resilience strategy that articulates the priorities, means, and ways to advance the resilience of the Nation.”
Key takeaway: While a national resilience strategy sounds great under any other administration, I am extremely wary of what such a strategy could mean for Trump 2.0. Furthermore, this strategy already exists! In January 2025 the Biden administration released a National Resilience Strategy which was one of the many pieces of climate change resilience-related initiatives the Trump administration revoked. It’s hard to imagine a national resilience strategy that doesn’t address the climate crisis front and center.
A recent Forbes article underscores how climate change has ripple effects throughout the economy and is forcing how and where people live, shaking up real estate and insurance markets, and wreaking havoc on local governments and challenging their ability to provide basic services. And those who are hurt first and worst by climate change-related impacts are often those who live in the riskiest areas with the least resources. This is where and why decision-makers include an equity lens in any kind of disaster assistance, adaptation or resilience strategy.
My colleague Melissa Finucane explains that “without a focus on racial equity, disaster policies don’t just leave these communities behind, they in fact compound the health, environmental, and economic challenges being faced.”
It’s hard to imagine a valuable national resilience strategy being developed within a three-month timeframe. Based on what we’ve seen so far, one thing is for sure: we can expect the Trump administration’s national resilience strategy to be radically different from the Biden administration’s plan. It will also likely be in stark contrast to how climate scientists, policy and planning experts, emergency and floodplain managers understand resilience and how such strategies should be developed and informed by the latest science and public input, prioritizing the needs of communities that have the fewest resources.
3. Review and revise national critical infrastructure policies
Section 3(b) directs the President’s National Security Affairs Assistant, in coordination with the Director of the Office of Science and Technology Policy (OSTP) and heads of relevant agencies, to review all critical infrastructure policies within 180 days and recommend “revisions, recissions, and replacements necessary to achieve a more resilient posture; shift from an all-hazards approach to a risk-informed approach; move beyond information sharing to action; and implement the National Resilience Strategy…”
Key takeaway: Important policies that could be revised include the National Security Memorandum 22 “NSM-22” of April 30, 2024 (Critical Infrastructure Security and Resilience) which replaced Presidential Policy Directive 21 (PPD-21). What I am particularly concerned about is what this administration might do to NSM-22, which was updated after a decade to address new complex threats, and while it has not been revoked, it has been taken down from the White House website. The modernized policy builds on PPD-21 and strengthens it by: 1) encouraging the private sector to comply with minimum resilience standards; 2) adding key new developments such as transitioning energy and transportation sectors away from fossil fuels; and 3) includes emerging threats such as climate change and supply chain disruptions.
Given the fact that this president has dismantled many federal advisory councils, I hope the administration will maintain and include the National Infrastructure Advisory Council (NIAC) in this process, as it has been very productive in producing “30 in-depth studies” with many important recommendations—including this related one that the nation must “Better prepare and respond to disruptions (like Superstorm Sandy) that can ripple across multiple infrastructure systems and paralyze services to entire regions.”
I will keep an eye out for how the administration will implement the “shift from an all-hazards approach to a risk informed approach” as the language leaves emergency manager-types scratching their heads. The NSM-22 updates the term all hazards “as all threats, all hazards” and defines this term as “a threat or an incident, natural or manmade, that warrants action to protect life, property, the environment, and public health or safety, and to minimize disruptions of Government, social, or economic activities. It includes, but is not limited to: natural disasters, cyber incidents, industrial accidents, pandemics, acts of terrorism, sabotage, supply chain disruptions to degrade critical infrastructure, and disruptive or destructive activity targeting critical infrastructure.”
A risk informed approach is one that evaluates all potential threats and hazards, identifies exposure and vulnerability. So could this be the administration’s “streamlined” and “efficiency” approach to removing any climate change-related risk such as sea level rise? Or, is instead a throwback to a time prior to the PPD-21’s “all-hazards” risk approach to one that is more focused on the risk of counterterrorism and infrastructure assets?
4. “Streamlines” the national continuity policy
Section 3(c) of the executive order calls for a review of all national continuity policies and recommendations to the president from this review within 180 days of this order. Specifically, it states that the President’s National Security Affairs Assistant, in coordination with the heads of relevant agencies, “shall review all national continuity policies and recommend to the President the revisions, recissions, and replacements necessary to modernize and streamline the approach to national continuity capabilities, reformulate the methodology and architecture necessary to achieve an enduring readiness posture, and implement the National Resilience Strategy described in subsection (a) of this section.”
Key takeaway: Continuity policies are just what they sound like, they provide a coordinated approach in the case of an emergency whether a natural hazard, or other type of disaster. Each of these different pieces of policies tie into each other and highlights that the administration could indeed be dismantling FEMA policy by policy, in this case by FEMA’s continuity policy and toolkit which helps ensure FEMA’s essential functions continue in the case of emergencies but also helps communities understand how to maintain their functionality.
I’m concerned that a so-called “streamlined” approach to continuity policies could mean some critical pieces of budgets could be cut and interagency projects and initiatives won’t be supported, all of which will make communities less resilient.
5. Review and revise preparedness and response policies
Section 3(d) of the executive order calls on the President’s National Security Affairs Assistant and other relevant agencies’ heads to review national preparedness and response policies and recommend revisions, recissions, and replacements necessary to the President to “reformulate the process and metrics for Federal responsibility, move away from an all-hazards approach,” and implement the National Resilience Strategy within 240 days of the order.
Key takeaway: Instead of building on the many years of plans and guidance on preparedness, this administration is underscoring the desire to downsize the federal responsibility and ensure this “reformulation” is reflected in the new national resilience strategy. In under eight months or sooner, the Trump administration will have developed new policies and metrics on what the federal role is in national preparedness and response and what this will look like for states and other jurisdictions.
If the administration takes a hatchet to the current policies, we’ll likely see changes in policies and guides such as the National Disaster Recovery Framework that outlines five main areas including federal support to states and local jurisdictions and emphasizes the need for resilient and sustainable recovery planning and the National Response Framework which helps communities, citizens, business, and others to build response plans. We will also have a better idea about what moving away from an “all-hazards approach” will look like —which doesn’t sound good no matter how you slice it.
6. Develop a national risk register
Section 3 (e) of the executive order calls for a national risk register to be developed within 240 days of this order. Specifically, the order charges the President’s National Security Affairs Assistant, in coordination with the Director of the Office of Management and Budget (OMB) and the heads of relevant agencies, to coordinate the development of a national risk register “that identifies, articulates, and quantifies natural and malign risks to our national infrastructure, related systems, and their users. The quantification produced by the National Risk Register shall be used to inform the Intelligence Community, private sector investments, State investments, and Federal budget priorities.”
Key takeaway: To my knowledge, a national risk register does not exist, however the NSM-22 establishes a coordinated approach to federal risk management for critical infrastructure, Cybersecurity and Infrastructure Security Agency (CISA) has a national risk management center and FEMA developed a National Risk Index (NRI) which, while it has its flaws, is a tool for communities to see the level of risk for 18 hazards and overlays of social vulnerability, community resilience and expected annual loss. FEMA also had a climate change risk tool as well called the Future Risk Index that FEMA under the Trump administration (of course) removed, but fortunately scientists recovered and is available for free on GitHub.
The bottom line is, if the Trump administration does not account for climate change within the new risk register, it’ll fail to do its job to quantify the risks to the nation’s infrastructure and will cause a moral hazard.
7. “Streamlines” preparedness and continuity organizational structure
Section 3(f) calls on the Secretary of Homeland Security to “streamline” the federal governments’ current national preparedness and continuity organizational structure that spreads across five major functions within one year “to ensure State and local governments and individuals have improved communications with Federal officials and a better understanding of the Federal role.” The functions include: 1) the National Essential Functions, 2) Primary Mission Essential Functions, 3) National Critical Functions, 4) Emergency Support Functions, 5) Recovery Support Functions, and 6) Community Lifelines.”
Key takeaway: Each of these functional categories plays a role in FEMA’s mission. Similar to changes in the related policies above, a simplified and streamlined version would do a disservice to FEMA’s ability to fulfill its mission. Agency staff know what to do, so it would take time and resources away from other efforts to train the federal family in learning and implementing a new organizational structure in time for hurricane season.
What’s next?
UCS will closely watch the outcomes of this executive order and this administration’s continued attacks on FEMA because it’s crucial that communities are protected and not sacrificed in the name of harmful and disingenuous efforts purported to advance “efficiency” and “streamline” the federal government’s response to disasters.
We’ll have to wait to have many questions answered as much of the implementation of the EO will be reviewed, written and decided behind closed doors. In the interim, the FEMA Review Council just released a request for information to the public to provide comments on improvements to, and overall experience with FEMA during disasters, which are due May 15, 2025. This is a critical opportunity for the public to weigh in on how important FEMA is in coordinating a “whole-of-government response in the period immediately after a disaster” – as two former FEMA administrators wrote.
Genuine reforms to FEMA should be informed by science, expertise, and the experiences of disaster survivors. Instead, this administration seems hell-bent on a cruel campaign of decimating an agency that millions of people rely on to stay safe and get back on their feet after floods, fires, hurricanes and more.
Given the actions planned to continue to downsize FEMA, including reducing staff even further, streamlining the mission and staff roles and the geographic footprint of the 10 FEMA regional offices, we need bipartisan defense of the agency. This should be a clarion call for lawmakers to keep communities safe by preserving resources meant for FEMA and making science-informed and evidence-based changes to the agency.