By Gabe Cohen and Ella Nilsen

(CNN) — Trump emergency management officials are discussing reforms that would make it much harder for communities to qualify for federal disaster assistance, honoring President Donald Trump’s executive order to shift more responsibility for disaster response and recovery to states rather than the federal government.

A memo from acting FEMA administrator Cameron Hamilton, a Trump appointee, obtained by CNN, outlines a long list of recommendations for Trump to follow that could drastically reduce the number of emergency declarations the president approves and the amount of federal assistance doled out to cities and states hit by natural disasters.

Such a change ahead of what are typically the worst months for natural disasters across the US could pose significant problems for states that are unprepared to foot the bill and for the millions of Americans impacted by disasters every year.

Most notably, the memo, sent to an official with the White House Office of Management and Budget, proposes dramatically raising the threshold for states to qualify for public assistance, effectively quadrupling the amount of damage a community must suffer in order to receive federal aid.

The proposal also recommends reducing the share of recovery costs the federal government will pay, limiting the types of facilities eligible for assistance and denying all major disaster declarations for snowstorms.

“The primary purpose of this memorandum is to identify short-term actions to rebalance FEMA’s role in disasters before the start of the 2025 hurricane season,” Hamilton writes in the memo, which is part of the administration’s ongoing effort to dramatically shrink the disaster relief agency’s footprint and cut federal costs for disasters.

At this point, there’s no clear indication that FEMA or the White House are following the recommendations outlined in Hamilton’s proposal.

CNN has reached out to The White House Office of Management and Budget, FEMA, and the Department of Homeland Security, which oversees FEMA, for comment.

While the effort to reduce the burden on the federal government is not without its supporters, some worry that the proposed changes are too much, too soon.

“Is it going in a direction that it needs to go? Yeah, I think so. But going there immediately is going to be very painful,” former FEMA Administrator Craig Fugate, who served under the Obama administration, said of the proposed changes.

Eliminating small disaster declarations

When a state requests a major disaster declaration, FEMA uses a metric that measures the estimated cost of the assistance against the state population – known as the Per Capita Indicator (PCI) – to evaluate the severity of the damage and inform its recommendation to the president on whether to approve public assistance.

Hamilton’s proposal would increase the PCI from $1.89, its current level, to $7.56, which would focus federal funds on large-scale disasters and “eliminate small disaster declarations.”

Hamilton argues such a change would “reduce Federal costs by hundreds of millions annually” and better reflect inflation and current economic conditions, given these thresholds have hardly increased in recent decades.

Previous administrations have discussed raising the PCI, which was established in 1986 and set at $1. A 2011 government report called the indicator – at that point only $1.35 – “artificially low” because its modest growth didn’t properly reflect increases in personal income and inflation; with those factors taken into account, the report said the indicator would have been at $3.57 in 2011

But state emergency managers told CNN a threshold increase of the magnitude proposed by Hamilton would pose a huge challenge when future disasters hit.

“That’s a massive increase,” said Karina Shagren, communications director for the Washington Military Department, which oversees the state’s emergency management. “We’re fully anticipating that states are going to have to take on a larger burden to respond to emergencies. We just need some clarity. We’re trying to develop a path forward without really knowing what the path looks like.”

North Carolina Emergency Management spokesman Justin Graney told CNN the proposed increase was “alarming.”

Rural communities, especially in large states, could struggle most to fill the gaps. Those areas often suffer severe, but concentrated damage, and may not qualify for public assistance under a much higher threshold.

“States are not prepared today,” said Michael Coen, former FEMA chief of staff under the Biden and Obama administrations. “If they were given notice, and they could work with their state legislatures, they could prepare and budget to be able to handle the risks that they know they have. But doing this without giving states any advanced notice would leave them in dire straits.”

Federal disaster declarations have risen steadily in recent years, as extreme weather becomes increasingly destructive and costly in a warming world.

Coen called the proposal to increase the PCI fourfold “unprecedented.”

“It would adversely affect states that have a lot of risk and don’t have the financial capability to respond,” Coen said. “Americans that live in these communities are going to see a delay in their recovery.”

Disaster declarations denied in blue and red states alike

It is unclear whether the memo and the high threshold it proposes are tied to recent White House denials of major disaster declarations for some states, including Arkansas, Washington state and Kentucky.

The Trump administration recently denied Washington state’s request for FEMA public assistance after a deadly bomb cyclone last year. The state submitted $34 million in verified damages – more than twice FEMA’s current threshold to warrant federal assistance.

Washington met “all” of the “very clear criteria” to qualify for disaster funding, Gov. Bob Ferguson, a Democrat, wrote in a statement after Trump’s denial, adding it was “another troubling example of the federal government withholding funding.”

Shagren said the federal government has not indicated to her state that it is planning to change the threshold for assistance. Washington state is planning to appeal the federal government’s denial of a major disaster declaration.

But it hasn’t just been blue states that have been shut out of assistance.

As CNN has reported, the Trump administration denied Arkansas GOP Gov. Sarah Huckabee Sanders’ request for individual and public assistance following an outbreak of severe storms and tornadoes that also affected neighboring Mississippi and Missouri and left more than 40 people dead.

The denial of the request, dated April 11, said the Trump administration had “determined that the damage from this event was not of such severity and magnitude as to be beyond the capabilities of the state, affected local governments, and voluntary agencies. Accordingly, we have determined that supplemental federal assistance is not necessary.”

Sanders, a longtime Trump ally and his former press secretary, is appealing the decision to the White House, saying in a statement “without the support of a Major Disaster Declaration, Arkansas will face significant challenges in assuming full responsibility and achieving an effective recovery from this event.”

The tornado ripped through rural Arkansas in March, leveling homes, churches and stores in a town called Cave City, leaving three people dead.

Cave City resident Irma Carrington, who runs a local business called Crystal River Cave Tours, said the town’s grocery store, pharmacy, dental office and multiple churches were badly damaged by the tornado. The town is still without its grocery store, and individuals who lost homes have been relying on home insurance or their personal savings to build back.

Carrington told CNN she was frustrated at the lack of federal help for the area.

“I would not be too happy with our government if they don’t step in and step up when we need it the worst,” Carrington said. “Our whole town has been affected. Our people pay taxes like everybody else. I don’t understand why we’re not getting it, I would think we’ve had plenty of damages.”

Balancing state and federal funds

The memo also proposes the president keep the federal cost share for disaster recovery from exceeding 75% – meaning the federal government covers 75% of the recovery and the state and local governments pay the remaining 25% – which is standard for most disasters but is sometimes elevated after particularly devastating storms.

Until recently, North Carolina was awarded 100% federal cost share for recovery from Hurricane Helene. This month, Trump denied extensions for the state, bringing the federal cost share down to 90% moving forward.

The administration will also consider eliminating public assistance for recreational facilities (like parks and boat docks) and denying all major disaster declarations for snowstorms.

During the Obama administration, the former FEMA officials said, the agency repeatedly raised the threshold for states to qualify for federal assistance after a snowstorm, given the burden the disasters placed on the federal government to fund large-scale snow removal. But no administration has outright barred states from receiving major disaster declarations from a snowstorm.

Trump and his allies have criticized FEMA for months as ineffective and unnecessary. Homeland Security Secretary Kristi Noem, whose department oversees FEMA, has vowed to “eliminate” the agency.

Fugate, the former FEMA administrator, hopes the proposal sparks a bipartisan conversation about reforming the agency rather than dismantling it.

“This would be pretty drastic, but maybe it will start a more meaningful discussion on the policy side,” Fugate said of the proposal. “What is the proper balance between you as a federal taxpayer subsidizing states that are building in high hazard coastal areas, that are profiting from that development, but you’re basically their insurance policy.”

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