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inflation for the years between 1986 and 1999. 513 As a result, the indicator has only risen 37<br />

percent, from $1.00 to $1.37, since 1986. Meanwhile, inflation over that period would have<br />

increased the indicator from $1 of damage to $2.15 in 2014. 514<br />

GAO analyzed actual and projected obligations for 508 disaster declarations which<br />

received Public Assistance grants during fiscal years 2004-2011. 515 It found that fewer disasters<br />

would have been declared had FEMA updated the indicator to consider increases in personal<br />

income or price inflation for all of the years since 1986. Specifically, GAO found that nearly<br />

half—a full 44 percent—of those disasters would not have met the threshold indicator if the<br />

indicator had been adjusted for changes in income, and that 25 percent would have failed to<br />

qualify had the per capita damage indicator been adjusted for inflation. 516<br />

The use of the per capita damage indicator also creates a bias in favor of declaring<br />

disaster in small-population states. Because the indicator is determined by dividing the dollar<br />

amount of damage by the state’s population, a state with a low population can meet FEMA’s<br />

threshold of $1.37 with a lower amount of damage than a state with a larger population. For<br />

example, in 2013, a major winter storm hit a broad part of the northern Texas and southern<br />

Oklahoma. Both states applied for disaster relief. The estimated amount of damage in Oklahoma<br />

was $6.4 million, which amounted to a statewide damage indicator of $1.70, which met FEMA’s<br />

per capita damage threshold, and led to a declaration covering a number of counties that border<br />

Texas. 517 The preliminary damage assessment for the same winter storm in Texas was $30<br />

million, 518 which fell $5 million short of the number needed to get Texas above the per capita<br />

damage indicator. As a result, FEMA denied Texas’s request for a major disaster declaration in<br />

513 U.S. Government Accountability Office, “Improved Criteria Needed to Assess Jurisdictions Capability to<br />

Respond and Recover on Its Own,” GAO-12-838, September, 2012, pg. 24,<br />

http://www.gao.gov/assets/650/648162.pdf<br />

514 “CPI Inflation Calculator,” http://data.bls.gov/cgi-bin/cpicalc.pl, accessed May 23, 2014.<br />

515 U.S. Government Accountability Office, “Improved Criteria Needed to Assess Jurisdictions Capability to<br />

Respond and Recover on Its Own,” GAO-12-838, September, 2012, , pg. 24;<br />

http://www.gao.gov/assets/650/648162.pdf,.<br />

516 U.S. Government Accountability Office “Improved Criteria Needed to Assess Jurisdictions Capability to<br />

Respond and Recover on Its Own,”, GAO-12-838, September, 2012, , p. 24;<br />

http://www.gao.gov/assets/650/648162.pdf,.<br />

517 “Oklahoma – Sever Winter Storm,” FEMA.gov, January 30, 2014; pg. 2, http://www.fema.gov/media-librarydata/1393619267269-e777eab6d237c9da9fce6405e2c9107a/PDA+Report+FEMA-4164-DR-OK.pdf,<br />

.<br />

518 “Texas Severe Winter Storm – Denial of Appeal,” FEMA, April 15, 2014; http://www.fema.gov/medialibrary/assets/documents/95015,.<br />

111

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