Testimony of John R. Vaughn, Chairperson
National Council on Disability (NCD)
Subcommittee on Economic Development, Public Buildings,
and Emergency Management
Transportation and Infrastructure Committee
U.S. House of Representatives
"Looking out for the Very Young, the Elderly and Others with Special Needs: Lessons from Katrina and other Major Disasters"
Tuesday, October 20, 2009
2167 Rayburn House Office Building
Ms. Chairwoman, Ranking Member Diaz-Balart, and Members of the House Transportation and Infrastructure Subcommittee on Economic Development, Public Buildings, and Emergency Management:
On behalf of the National Council on Disability, thank you for the opportunity to testify today on NCD's research regarding procedures and plans in place for the aid of children and adults with disabilities during and after natural disasters.
NCD and Its Role in Emergency Preparedness
NCD is composed of fifteen members, appointed by the President, with the consent of the U.S. Senate, and a staff of 10 that supports the Council's work. The purpose of NCD is to promote policies, programs, practices, and procedures that guarantee equal opportunity for all individuals with disabilities and that empower individuals with disabilities to achieve economic self-sufficiency, independent living, and integration into all aspects of society. To accomplish this, we gather stakeholder input, review federal programs and legislation, and provide advice and recommendations to the President, Congress and government agencies. Much of this advice comes from timely reports and papers NCD releases throughout each year.
NCD has provided advice on emergency management through publication of several reports and papers over the last several years. Just prior to and following Hurricanes Katrina and Rita, NCD released the following report and papers:Saving Lives: Including People with Disabilities in Emergency Planning (April 2005); The Needs of People with Psychiatric Disabilities During and After Hurricanes Katrina and Rita: Position Paper and Recommendations (July 2006); and The Impact of Hurricanes Katrina and Rita: A Look Back and Remaining Challenges (August 2006).
As a result of NCD's work, the 2006 Homeland Security Appropriations bill's Post-Katrina Emergency Management Reform Act (PKEMRA) (H.R. 5441) required FEMA to employ a National Disability Coordinator and to interact, consult, and coordinate with NCD on a list of eight other activities. These duties included interacting with stakeholders regarding emergency planning requirements and relief efforts in case of disaster; revising and updating guidelines for government disaster emergency preparedness; evaluating a national training program to implement the national preparedness goal; assessing the nation's prevention capabilities; identifying and sharing best practices; coordinating and maintaining a National Disaster Housing Strategy; developing accessibility guidelines for communications and programs in shelters and recovery centers; and helping all levels of government in the planning of evacuation facilities that house people with disabilities. Congress provided $300,000 in the FY 2007 appropriations bill to enable NCD to fulfill our assigned duties under the PKEMRA. That funding has enabled us to complete our most recent report entitled Effective Emergency Management: Making Improvements for Communities and People with Disabilities.
Based on ongoing policy and research work, NCD identified a major gap in the government's knowledge base involving the availability and use of effective practices for community preparedness and response to the needs of people with disabilities in all types of disasters. In an effort to fill this gap, NCD collected more information about promising practices from emergency management organizations, a public consultation, and public testimony received in writing and at Council meetings held throughout the country. The Effective Emergency Management report provides examples of effective community efforts with respect to people with disabilities, and evaluates many emergency preparedness, disaster relief, and homeland security program efforts deployed by both public and private sectors. Finally, the report offers recommendations based on scientific research and thorough review of policies and practices that have been tested in emergencies of all types. It is our hope that this report will promote a focused dialogue and communicate critical information to be used by those charged with protecting our nation's most vulnerable populations.
The testimony that follows, like our Effective Emergency Management report, is ordered by phase of the disaster life cycle – preparedness, response, recovery, and mitigation. Each section of the testimony will provide a condensed overview of the current status of adults and children with disabilities during each phase of the disaster life cycle, including a summary of the challenges that persist, and will include a few selected recommendations NCD suggests for the Committee's consideration to assist in improving outcomes during and after disasters in the future. Each of these sections, as well as the recommendations, is developed in far greater length in our Effective Emergency Management report.
People with Disabilities and Disasters, Generally
According to the U.S. Census Bureau, approximately 54 million Americans, or roughly 20% of the total population, have disabilities. Disability affects all people of all ages. Disability can be acquired genetically, at birth, through an accident or injury, or naturally as part of the aging process. No matter how severe nor how attained, no individual with a disability should be left out of making plans for disaster preparedness, response, recovery, and mitigation.
Despite the notable percentage of the population that people with disabilities represent, according to a 2007 Harris Interactive survey released by the National Organization on Disability (NOD), 58 percent of people with disabilities reported not knowing whom to contact about emergency plans for their community. 61 percent reported not having made plans to quickly and safely evacuate their home. And amongst those employed full- or part-time, a full 50 percent reported having made no plans to safely evacuate their place of employment.
Through the purposed actions of federal, state, and local emergency planners as well as individual stakeholders, these figures must change. The alternative is a resignation to accept preventable casualties and deaths. A failure to plan is a plan to fail. This is a theme demonstrated through examples throughout this testimony and reflected in recommendations in each disaster phase section.
As noted in the Effective Emergency Management report's key findings, the greatest amount of work amongst the disaster phases has been done in the area of disaster preparedness. Nevertheless, a great deal of work remains needed in the areas of education and training, the design of warnings, and the provision of transportation and sheltering services. Additionally, while a number of resources provide recommendations for working with people with disabilities on disaster preparedness, very few actually show evidence of having implemented or evaluated these same strategies. Therefore, tested and refined strategies and initiatives remain sparse.
Historically, people with disabilities have been marginalized by the emergency management community. Instructions relating to the unique needs of people with disabilities have typically been limited to a few lines in an emergency plan, if they are mentioned at all. "Disabilities" have generally been placed into one large category, without consideration for the unique needs associated with each type of disability. Emergency planners have often decided what people with disabilities need without consulting those people. This practice further alienates people with disabilities and increases their vulnerability during disasters. In recent years, Congress and the White House have demanded that emergency planners afford people with disabilities the same consideration during emergency planning as all other individuals. Although some improvement in this area is evident, catastrophic events, such as Hurricane Katrina and the California wildfires, continue to expose the gaps that still exist in many emergency plans and preparedness efforts. These events reinforce the need for additional action.
Practical Barriers to Preparedness for People with Disabilities
Although ultimately everyone, including people with disabilities, is personally responsible for his or her own safety and must actively prepare for a disaster, this proves difficult for many individuals with disabilities whose income is often well below national norms. When an individual must rely upon discretionary income to pay for emergency kits, transportation costs for evacuation, temporary shelter expenses, and ongoing recovery needs, and discretionary income is little to none, execution of these steps is often impractical. Another practical barrier is that disaster preparedness remains low in most peoples' list of priorities, and for people with disabilities who often have long lists of other unmet needs, this situation is no different.
People with Disabilities are Routinely Excluded from Preparedness Activities
Unlike many of their nondisabled peers, people with disabilities are routinely excluded from preparedness exercises, drills, and other planning processes. As noted in one study of 30 disaster sites, only 27 percent of emergency managers had completed available training on disabilities, and fully 66 percent of the counties had "no intention of modifying their guidelines to accommodate the needs of persons with mobility impairments" because of problems stemming from costs, the availability of staff, awareness, etc. This lack of involvement in disaster planning also compromises emergency planners' credibility to people with disabilities when hazard and preparedness information is disseminated. The likeliest solution is found in a partnership approach to preparedness planning that brings disability organizations, with which people with disabilities may already be familiar, to the table with emergency planners.
One-Size-Fits-All Approaches Do Not Work
People with disabilities are often grouped together as a homogenous unit in preparedness recommendations, which does not adequately account for the range of differences that exist between disabilities or the accompanying range of issues that emergency managers must prepare for to successfully respond to this diverse population. Generic, one-size-fits-all approaches to disaster planning do not work. Each type of disability presents its own unique set of barriers during disasters. For example, people with hearing disabilities may not receive weather warnings that broadcast only over audible technologies, whereas the most urgent concern of people with mobility disabilities may be negotiating the stairs of a fire escape during evacuation. In Executive Order 13347: Individuals with Disabilities in Emergency Preparedness, President Bush called for emergency managers to "consider, in their emergency preparedness planning, the unique needs of agency employees with disabilities and individuals with disabilities whom the agency serves." Indeed, addressing barriers created by the "unique needs" of people with disabilities, rather than focusing narrowly on disability, can serve to better protect all people during times of disaster. Children, seniors, and people with disabilities all benefit from an expanded set of options to support those at risk during an event.
People with Disabilities as Active Participants in Preparedness Planning
As noted in our Effective Emergency Management report, people with disabilities must be actively involved in the planning process for several reasons:
- First, their knowledge of potential barriers is invaluable. People with disabilities are excellent choices to serve as consultants or advisors during emergency plan development;
- Second, their personal experience in overcoming these barriers adds tremendous validity to plan solutions; and
- Third, the empowerment experienced through participation may prompt people with disabilities to take preemptive actions on their own and encourage others to follow suit.
Invited participants must be representative of all types of disabilities. Equal representation is imperative, as each disability can present unique challenges to consider during emergency plan development. For example, people with only mobility disabilities can receive warnings via ordinary technology, but they may not be able to self-evacuate; whereas people with hearing disabilities may be able to self-evacuate, if they are properly notified. Advocacy groups that work for people with disabilities should also receive an invitation to the planning table. The collective knowledge gained by including these individuals and organizations is invaluable to plan development. In addition, the individuals or groups responsible for implementing the plan, such as first responders, should also be involved in the process. The insight gained through working side by side with people with disabilities during the plan development process will enhance everyone's understanding of the plan's purpose.
Regional Coordinators Could Create Crucial Linkages
PKEMRA established the creation of the national disability coordinator position at FEMA, which marked a critical step in institutionalizing staff positions representing disability interests. Despite a variety of encouraging work seen to date from the national coordinator, given the number of disasters each year (The Center for Research on the Epidemiology of Disasters reported 22 major natural disasters in 2008 alone, affecting 17 million people in the United States) as well as the local disability concerns that emerge unique to each disaster, regional replication of the national coordinator position is vital. Regional coordinators similar to the National Coordinator's position, set up in each regional FEMA office, could enhance the effectiveness of the national disability coordinator by drilling down on local disability issues to more aggressively and timely respond to the needs of people with disabilities in disasters. Regional coordinators could liaise between voluntary agency liaisons and voluntary organizations that function in the National Response Framework and could oversee disability task forces that would go a long way in shoring up communication linkages between the local disability community and emergency managers.
Education and Training
Since most people have limited experience with disasters, educational programs are essential components of effective preparedness planning. Increasing the awareness of people with disabilities through disaster-related education programs is likely to lead to increased confidence and self-reliance. Education programs should instruct individuals and families how to prepare for disasters, especially sudden onset events. The materials and formats used in these disaster education programs must be developed in such a manner that they are accessible to people with all kinds of disabilities in both format and content. Periodic reviews of the information are essential to ensure that instructions reflect current research and practices. Avenues of distribution for this information should include the following:
- Organizations: People with disabilities may rely on a wide range of organizations, including social service, health, advocacy, community-based, disability, and other organizations. Professional associations for people with disabilities and disability community groups (music, dance, poetry, theater) can also be used. It is most practical to attempt to distribute information to people where they live, eat, work, worship, recreate, and socialize.
- Public meetings and workshops: These can be used not only to formally present information but to encourage the exchange of information among attendees. Public meetings work best when the number of attendees is relatively small. A neighborhood meeting is a good example of this method.
- Brochures, door hangers, and other printed materials: Printed materials are a rather simple but effective method of dispersing information. These materials should be available in Braille as well as other languages to ensure that everyone has access to the information.
- Issue presentations and panel discussions: These are similar to public meetings but could involve larger audiences, as attendees are primarily there to receive information. Examples include professional associations, civic clubs, and advocacy organizations.
- Radio talk shows, chat rooms, social networking sites, disability blogs, and email blasts: These informal mediums are less intimidating to most people and are generally accessible from any location via phone or computer.
- Web-based information: The Internet is fast becoming the information source of choice. In most cases, people are able to quickly access multiple references to almost any topic without leaving their homes.
- Degree programs: Colleges and universities should be encouraged to integrate an awareness of the needs of people with disabilities into their degree programs, especially emergency management, fire sciences, social sciences, social services, and gerontology, to name a few.
Training offers an avenue to evaluate the concepts and measures or recommended procedures contained in an emergency preparedness plan while simultaneously enhancing the proficiency of participants, both individuals and organizational representatives or staff. Examples include practice sessions, live drills, and tabletop exercises. These events should take place in a controlled environment that both teaches and tests emergency procedures. On an individual level, practicing and adapting a personal evacuation plan is vital to ensuring that protective actions work and become familiar. The development of responsive habits is the first line of defense against any type of disaster, especially rapid onset events.
Emergency responders also need training in recognizing and understanding the needs of people with disabilities. Most emergency responder training comes from practical exercises or emergency simulations. In similar fashion, firefighters should use tools, such as the etiquette guide developed by Oklahoma Able Tech and Fire Protection Publications, during training sessions to increase their awareness of the needs of people with disabilities. Additionally, people with disabilities must be actively involved in preparing, conducting, and overseeing training exercises. Their expertise in proper lifting techniques, ways of communicating, and handling other barriers that are often overlooked will greatly benefit emergency responders in their response preparations. This perspective and insight into the unique needs of people with disabilities will enhance the effectiveness of training simulations and identify areas for improvement.
Pre-event planning is crucial for the successful evacuation of people with disabilities, as the time and resources necessary for their evacuation often exceeds that required for individuals without disabilities. Timing is not the only issue associated with evacuating people with disabilities. The U.S. Government Accountability Office (GAO) documented a number of challenges during recent evacuation events, including identifying people who need evacuation assistance, securing adequate transportation, and coordinating the evacuation efforts. Evacuation protocols are still emerging and lack empirical validation through scientific studies. FEMA has recently established regional agreements with paratransit services to provide support and, as of February 2009, the Federal Highway Administration was reviewing draft guidance for special needs evacuation.
Rapid-onset evacuations often prove more difficult, even under the best of circumstances. In 2004, the California State Independent Living Council (SILC) issued a brief entitled "The Impact of 2003 Wildfires on People with Disabilities" and found that people who were deaf were not notified adequately of the wildfires. Emergency personnel raced ahead of the fast-moving fires and announced evacuation orders using car loudspeakers. Few reports on television were close-captioned. Similarly, people who were blind often went without notification as well. Many remote areas did not have television or radio access and none had reverse 9-1-1 capabilities. According to the brief, sometimes "those notified to evacuate were not advised which direction to flee, or what location could be used as an emergency gathering point."
Sheltering in Place
An alternative to evacuation when faced with a rapid onset disaster, such as a hazardous material release, is to seek refuge inside a structure. This is known as sheltering in place. The object of sheltering in place is to limit, if not eliminate, exposure to the outside air. Sheltering in place may be problematic for people with disabilities for several reasons. First, people in the "lowest income quartile [are] less likely to want to attend classes on creating a home shelter environment and to have a family plan or preparedness kit" in place to do so, and people with disabilities often fall into this lower income quartile. Second, people with disabilities may experience difficulties with the physical labor necessary to create a home shelter. The limitations of their disability could prevent them from setting up a shelter or increase the amount of time necessary to do so, leaving them vulnerable to airborne contaminants for an extended period. A separate but similar issue may occur among individuals with cognitive disabilities, who may have difficulty understanding instructions for sheltering in place. This includes people with significant cognitive disorders and those with Alzheimer's. A third problem with sheltering is the lack of accessible options; for example, most underground safe rooms in tornado alley are not accessible.
In view of many of the most serious ongoing challenges to the disability community within the preparedness phase of disasters, NCD elevates the following recommendations for Congressional consideration:
- Protect and maintain independence – Policies focusing on disaster preparedness should strive to protect and maintain the independence of people with disabilities. This includes addressing issues such as appropriate warning systems, transportation services, and sheltering options—to name a few.
- Partnerships with disability organizations – Require federal agencies to include disability organizations as partners in all preparedness and outreach efforts, funds, grants, and programs.
- Universal design – Encourage adoption of universal design principles as a means to increase evacuation options for people with disabilities.
- Accessible warning messages – Request that GAO investigate noncompliance with FCC policies (regarding accessibility of emergency broadcasts).
- Regional disability coordinators – Positions similar to the National Disability Coordinator should be included in the structure of the regional FEMA offices. Regional disability coordinators could enhance the effectiveness of the national disability coordinator by addressing more localized disability issues. Emergency management offices at the state, local, and tribal levels should be encouraged to establish similar positions in their respective jurisdictions.
Policy and practice areas tied to disaster response include the delivery of emergency information, the actions of individuals in response to that information, and the implications of the built environment and often the barriers created by it for the evacuation of children and adults with disabilities in times of emergency. Largely, people with disabilities remain forgotten during the response phase of a disaster. Similar to as was reported above in the preparedness phase, when people with disabilities are remembered within response measures, they are often grouped into one homogeneous population and provided with instructions that are not appropriately communicated or that are impossible for everyone to follow. However, some recent Federal actions provide reason for cautious optimism for change.
Since Hurricane Katrina, the response phase has received more attention, in connection with people with disabilities, than any other phase in the life cycle of emergency management. Toward that end, FEMA and the DHS office of Civil Rights and Civil Liberties (CRCL) released a draft of the Comprehensive Preparedness Guide 301: Special Needs Planning (CRCL 2008, released August 15) as part of the Post-Katrina Emergency Management Reform Act. The intent of the guide is to focus on people with disabilities and other "special needs," as they are called in the plan. A very promising trend is found in this document on pages 4–5, where it mentions "special needs" as a "function-based approach…that addresses a broad set of common function-based needs irrespective of specific diagnosis, statuses, or labels (e.g., children, the elderly, transportation-disadvantaged)." Functional areas typically include maintaining independence, communication, transportation, supervision, and medical care. However, the term "functional needs" is not in widespread use across the nation, except in jurisdictions that have engaged in considerable research and planning (e.g., New York, because of its functional/medical needs shelter approach).
Problems Posed by the Built Environment
Historically, society has viewed disability through a medical model, which explains disability as one's personal, biologically-understood limitation, rather than through a socio-political model, which views disability as a consequence of faulty assumptions within the broader social, economic, and political environments. (The landmark civil rights law, the Americans with Disabilities Act (ADA), was written and is premised on the latter model.) Relying on the medical model to understand disability has had the consequence of deemphasizing examination of the built environment and social responsibility to create a safe setting for everyone. One research team remarked, "Traditional perspectives, based on assumptions of individual limitation, have shaped the construction of disabled people's vulnerability to natural hazards as tragic yet unavoidable." This is simply untrue. However, by ignoring the built environment, people with disabilities are further alienated and the safety of everyone who responds to an emergency or disaster is jeopardized.
Contributing to the issue of the built environment is the fact that "the most accessible entrances tend to be the best route out of the building for everyone; nondisabled people head there first in an emergency, thus clogging those exits intended for the disabled, who have no alternative exits." Researchers in this area promote the need to address the built environment as accessible to everyone, thus promoting safe disaster response rather than requiring and relying upon people with disabilities to understand and act on detailed instructions in an environment that is not supportive of their functional needs.
Communication Gap between Emergency Management and Disability and Aging Communities
Many of the problems incurred by emergency personnel during the response phase of a disaster could be addressed if planning included people with disabilities. It is imperative that people with disabilities have a voice and be at the table for all stages of disaster planning, including the development of policies that impact the built and social environments and, therefore, influence a person's ability to respond appropriately to disaster. Yet, the report from the Special Needs Assessment for Katrina Evacuees (SNAKE) project found that many emergency shelter planners had little interaction with the disability community prior to Hurricane Katrina. The following findings were presented in the SNAKE report:
- 50% of those interviewed had policies, plans and guidelines for disability accommodations in place prior to Hurricane Katrina. Only 36% had someone with expertise onsite to provide guidance regarding appropriate accommodations.
- 54% of the respondents did not have any working agreements with disability and aging organizations prior to the event. 50% made contacts with those organizations as a result of their Hurricane Katrina experience.
- The gap between emergency management and disability- and aging-specific organizations widened when the organizations serving these populations tried to connect with the emergency management community–85.7% of these community-based groups answered that they did not know how to link with the emergency management system.
As NCD noted in its written testimony last month to this Subcommittee, the current status of emergency warnings for people with disabilities is woefully inadequate. People who may have special communication needs for disaster warning messages include people who are deaf, deaf-blind, blind, or visually-impaired; the frail elderly; and those with cognitive disabilities. The existing and decentralized warning system in the United States, though offering extensive means for warning dissemination, largely relies on audible (possibly supplemented by visual) messages that are often transmitted through an intermediary. For many deaf and hard of hearing individuals, audible-only inclement weather warnings or Civil Defense sirens go unheard. Most disaster warnings are only broadcast via conventional media methods, so to the extent that conventional media remain inaccessible to people with hearing and vision disabilities, emergency information broadcast over them does as well.
Many blind or visually-impaired individuals are relying increasingly on television to meet communication needs, which has important implications in times of disaster. The FCC Media Security and Reliability Council is working with the American Foundation for the Blind (AFB) to develop standards to address the needs of individuals with vision loss during times of disasters. In the current absence of standards, on-air meteorologists often assume that consumers have good vision and can see the radar images, failing to accompany an emergency weather broadcast with proper audio cues as to location or trajectory. Recent technologies that project a storm's path, location, and time may be useful, but only if they are offered through audible means as well as through visual graphics.
For individuals who are deaf-blind, receipt of an emergency message often involves diverse communication needs. Large-print and tactile cues are preferred when available. Communication with individuals who are deaf-blind can range from sign language near the person's face to sign language in the palm to words written on the palm with a finger. The universal symbol for an emergency is a tactile symbol "X," "drawn" on the back of the deaf-blind individual by an individual who is alerting him or her. This symbol is understood to mean that an emergency has occurred and that it is imperative for the individual receiving the message to follow directions and not ask questions. However, few if any preparedness materials or training workshops include this information.
In addition to the numerous barriers to the initial receipt of the warning message, barriers also hamper a recipient's belief in the credibility of the message. Experts contend that the best way to extend warnings is through the use of people who are as similar to the target population as possible, using well-established officials familiar to the community to enhance credibility. Emergency management professionals can build their credibility among the disability community by involving people with disabilities in all stages of disaster response; this also helps achieve effective response in the community during times of disaster. Another strategy is to use public service announcements (PSAs) and warning messages disseminated by people who are known and trusted in the disability community.
Being able to see, hear, or understand that other people are taking shelter increases the likelihood that a person will take action. For people with sensory, cognitive, or psychiatric disabilities, taking shelter may be further delayed if confirmatory cues are not present. Solutions include accessible Public Service Announcements (PSAs) that show people with disabilities taking protective action, outreach efforts by people with disabilities or advocacy organizations, and direct appeals to people with disabilities, their families and friends, and service organizations.
To better meet the needs of all people, including people with disabilities, emergency managers must understand how people respond during a disaster warning. Knowing how to provide a warning message that will be well received and using a credible "voice" to deliver it are major steps toward motivating community members (including people with disabilities) to respond appropriately. By better understanding the steps taken by individuals who receive and hopefully respond to warning messages, emergency personnel can improve the likelihood that crucial instructions are followed.
Legal Implications for Evacuation of People with Disabilities
Many first responders incorrectly assume that everyone is able to evacuate safely without additional assistance. For many people with disabilities, however, unique evacuation barriers exist that must be addressed during the development and execution of evacuation plans. Based on Census data as well as the number of individuals who at any one time may be experiencing temporary disability (such as a broken leg), a considerable amount of a community's population will need additional assistance during an evacuation. In the Houston area alone, for example, at least 40,000 people required power for wheelchairs, ventilators, and similar equipment before Hurricane Ike. In FEMA's 2009 Citizen Corps national preparedness survey, nearly 4 in 10 individuals from the general population said they would expect to need help to evacuate or get to a shelter in the event of a disaster.
In 1999, citing Title II of the ADA, the Supreme Court ruled in Olmstead v. L.C. and E.W. that people with disabilities have the right to live in the community in a noninstitutional setting with proper services and supports as deemed appropriate by professionals. Title II of the ADA requires that public entities provide services to people with disabilities in the most integrated settings possible, or as appropriate to the needs of the individual with a disability (also referred to as "integration regulation") (Cornell University Law School Legal Information Institute n.d.). The implication of this court case in the construct of emergency planning is clear–since the landmark ruling, it is prudent to assume that every community is made up of individuals with disabilities living independently and that these individuals may be less likely to have the support of institutions during disaster. Plans must take this demographic knowledge into account.
In Savage v. City Place Limited Partnership, et al., a settlement was reached that forced Marshalls, a major retailer in 42 states and Puerto Rico, "to provide accessible evacuation routes for shoppers with disabilities in all of its stores...." (Gardner and Hollman 2005, para. 1). Katie Savage, who uses a wheelchair, filed a lawsuit after being trapped in a mall when Marshalls employees tried to force her to exit via an inaccessible path during an emergency evacuation. Savage became trapped in an underground portion of the facility, where she was unable to use the elevators. The Circuit Court for Montgomery County, Maryland, "found that the ADA requires places of public accommodation to consider the needs of people with disabilities in developing emergency evacuation plans." According to Elaine Gardner, director of the Disability Rights Project at the Washington Lawyers' Committee for Civil Rights and Urban Affairs: "The ADA always has been understood to help get people with disabilities into places of public accommodation. Now, for the first time, it also works to ensure that public places try to get those same people out in the event of a fire, terrorist attack, or other emergency" [emphasis added].
When evacuation is necessary, additional attention must be directed toward the availability of adequate transportation for individuals with disabilities and the technology or mobility devices they rely on (e.g., wheelchairs). According to the Survey of Hurricane Katrina Evacuees, the most common reason provided by respondents for not evacuating was "I did not have a car or a way to leave." In studying the aftermath of Hurricane Katrina among New Orleans residents, the Government Accountability Office (GAO) found that state and local governments did not "integrate transportation-disadvantaged populations" into their evacuation plans. GAO also found that most state officials did not believe that many of their residents needed transportation assistance, despite U.S. Census data to the contrary. Further emphasizing the importance of this consideration, the recent Citizen Corps 2009 survey showed that over half of the respondents reported needing help with transportation out of their area in the case of an emergency (55%).
When addressing people with disabilities who lack transportation and money, emergency planners must plan for the evacuation of assistive devices in addition to the person. These assistive devices are often custom fit for the individual and should be evacuated with him or her to ensure maximum independence, to lower reliance on emergency assets, and to speed post-event recovery. Service animals are also vitally important to their owners' ability to maintain independence and should be evacuated with the person. Guidance from the Federal Highway Administration is currently in draft form and subject to future release. The guidance describes a protocol for evacuation of people with disabilities and those in congregate locations from residence to reception center or shelter.
Nursing Home Evacuations
Deaths amongst nursing home residents in New Orleans following Hurricane Katrina highlighted the need to better plan and respond to the special needs in this population of people. Transportation and long-term living arrangements are the major factors in the evacuation of nursing home residents, many of whom have mobility and/or cognitive impairments. Evacuations are multi-tiered, as residents, their personal items, staff, and long-term medical needs must all be addressed.
When the National Disaster Medical System (NDMS) assists in the evacuation of hospital patients during natural disasters, it is not designed to aid in nursing home evacuations. Further, nursing homes and emergency management teams seldom work together. In its 2006 report, for these reasons, GAO requested that DHS "clearly delineate…how to address the needs of nursing home residents during evacuations."
Search and Rescue
Unlike other components of the response phase, rescuing disaster victims always occurs in an unpredictable and hazardous environment. For the reason of unpredictability of disasters, first responders do not preplan rescue operations but rather focus on practicing rescue techniques. It is during the practice of these fundamentals that guidance in lifting, moving, and communicating with people who have disabilities should be incorporated.
Because of our decentralized society, responsibility for the initial response to any disaster rests on the shoulders of the local government. Thus, the incorporation of special training in rescuing people with disabilities must be initiated at the local level. Most first responders approach all search and rescue assignments with the same mindset–get the victims out as quickly as possible. While speed may be of the utmost importance in these situations, first responders must also be careful not to exacerbate the situation. This is especially true in rescuing people with disabilities. First responders need to understand the unique abilities and limitations associated with different disabilities. This knowledge must then be transferred into rescue training and actual rescue situations. For example, first responders are cautioned not to use the over-the-shoulder carry when rescuing a person who uses a wheelchair. This carry can cause additional life-threatening injuries because of the health issues associated with the person's disability. Therefore, rescuers must practice multiple carrying techniques during training to be proficient in applying them during a rescue operation. In addition, first responders should attempt to rescue the victim's assistive technology, if at all possible. These assistive devices are often essential to the person's survival and will speed his or her recovery. Although rescuing these assistive devices should not take precedence over a human life, they should receive consideration when time and resources allow. The old adage "You will play the way you practice" holds true for rescue situations that do not allow the rescuer sufficient time to plan each step of the process.
The U.S. Fire Administration has developed a detailed guide, Orientation Manual for First Responders on the Evacuation of People with Disabilities, which should be incorporated into the standard operating procedures of local first responders. Although this guide is primarily aimed at evacuating people with disabilities, many of the concepts could be adapted for use in search and rescue operations.
The Americans with Disabilities Act mandates that accommodations, which include shelters, must be accessible. Shelters must also accommodate service animals and should provide multiple means for communication. Ideally, shelter staff should be trained to accommodate a wide variety of disabilities and medical needs. However, it appears that such training is not conducted routinely and that people with disabilities and those with medical conditions, as well as service animals, may be turned away from a general population shelter or sent to a special needs or medical shelter.
The National Organization on Disability (NOD) conducted a rapid survey of 18 shelters after Hurricane Katrina, supplemented with information from officials involved in response and sheltering efforts. Although two thirds of the shelters included questions regarding disability on their intake or registration paperwork, only minimal recognition of the disability occurred. Translating potential needs into available services lagged behind the intake identification. For example, only 30 percent of the shelters provided American Sign Language. Eighty percent did not provide TTY and 60 percent did not offer closed-captioned television. Although 56 percent posted written versions of oral announcements, people who were deaf or blind reported missing communications. Some shelters set up specific areas for communication, although such locations have been criticized as unnecessarily segregating people with disabilities.
Because of the rapid and chaotic evacuation of New Orleans, people with disabilities reported being separated from family members, who ended up in separate shelters. Disability organizations and schools worked to reunite families. One state school, for example, used its email and website capabilities to reunite families and opened the school as a shelter site for students and parents.
State officials reported that rescue efforts failed to include many pieces of durable medical equipment. Louisiana officials worked for six months, for example, to locate and reconnect expensive pieces of durable medical equipment with evacuees. Meanwhile, evacuees sent to shelters lost their independence because of the loss of their equipment; shelters scrambled to find temporary equipment that may not have fit the specific need; and shelters had to add staff to support individuals who had lost their equipment.
The ADA has opened doors for people with disabilities, resulting in more people with mobility, cognitive, sensory, or other limitations being out in the workplace and in public facilities. Legal settlements, such as the one for Katie Savage v. Marshalls, mandate that people with disabilities be aided in safely evacuating from public facilities, when necessary. Considerations for the special needs of residents in nursing homes, transportation for those who lack personal vehicles, search and rescue procedures that aid people with disabilities, and shelters that can accommodate this population segment are all issues that must continue to be addressed with the help of the disability community and solutions put into practice by emergency management professionals. NCD offers the following recommendations:
- Alternative warning systems – Policymakers should address public funds earmarked for civil defense sirens and use some monies for alternative warning systems.
- Improve the built environment – Support policies on international codes that affect the built environment and create safer settings for everyone, regardless of ability. By seeing to it that the built environment better meets the needs of the most vulnerable populations, policymakers can create an environment that improves response and evacuation outcomes for all populations.
- Specialized training for first responders – Add specialized training for first responders on rescue techniques for people with disabilities as a requirement for certain types of Homeland Security grants.
- Making shelters accessible – Since many shelter operations use existing building structures, funding needs to be made available to ensure that retrofitting and other modifications can be made so that any barriers are removed to make the facility more accessible when it is used as a shelter. Funding could occur in conjunction with the recently passed American Recovery and Reinvestment Act.
- Federal exercise evaluation – Require a performance evaluation and assessment for all federal exercises and disaster responses as standard operating procedure for after-action reports on disability issues.
The recovery time period is the least well researched phase in the emergency management life cycle. Coupled with a noted dearth of studies on people with disabilities, it is not surprising that only minimal efforts have been made to address disaster recovery for this population. A comprehensive research agenda must be generated to stimulate evidence-based practices, programs, and policies that can make a difference.
Technical reports, testimony, and other materials strongly suggest that the recovery phase is a problematic time for people with disabilities. Recovery planning is rarely conducted before a disaster in any jurisdiction, yet such planning can have great benefits for identifying post-disaster disability concerns. If disability issues are integrated into recovery planning, tremendous forward progress can be made.
As Hurricane Katrina revealed, considerable post-disaster challenges exist for people with disabilities, including:
- Difficulty finding temporary accessible housing;
- Lack of insurance coverage for specialized disability needs;
- Gaps in Federal assistance; a loss of access to health care; and
- Disruption of caregiver networks upon which many rely
Perhaps surprisingly, housing is one of the least examined areas of recovery research, despite its importance. Lower income housing tends to take a disproportionate hit during a disaster because it is likely to be older and less likely to be up to code; located in a floodplain or other hazardous area; and less structurally able to withstand an event (such as manufactured housing). Thus, seniors and people with disabilities at lower incomes presumably bear a higher risk of displacement from their homes.
Public housing can be problematic when it has been affected, particularly locations that are approved through the Section 8 Housing Choice Voucher Program. Although HUD maintains lists of available units across the nation, those units may not be located nearby. In past disasters, HUD and local housing authorities have identified and verified appropriate locations for replacement rentals. After the California wildfires in 2007, HUD established a new National Housing Locator System. The system invited prospective landlords and property owners to list units. Approximately 26,000 units were identified within a 300-mile radius of San Diego County. The list included the ability to search for accessible units, although additional concerns remained, including proximity to work, family, health care, banking, pharmacies, and other routinely accessed sources of support.
In New Orleans, public housing units remain unavailable while they are being rebuilt by HUD and area housing authorities. Concern has been expressed by local residents that the new units, which will be in mixed-income ranges, will displace or deter lower income residents. Finding housing near vital support systems needed by people with disabilities, the elderly, and people with medical conditions is also of concern. For example, relocation 100 miles away from a familiar senior center or dialysis center will be problematic.
After Hurricane Katrina, FEMA failed to provide temporary trailers that were accessible. In Brou v. FEMA (the Department of Homeland Security was also named in the suit), successful plaintiffs argued in a class action discrimination suit that the federal agency had not provided accessible trailers (e.g., with wheelchair ramps, maneuvering room, or grab bars), resulting in a longer wait for temporary housing. As another example, housing advocates have noted in conference presentations that mitigation elevations along the Gulf Coast displace people with mobility disabilities and senior citizens. Some organizations report that some of these people have been forced to choose congregate care over independent living. Brou v. FEMA was one of several efforts by the disability community that have resulted in changes at FEMA when it comes to disaster response and recovery. In another example, FEMA is incorporating disability-specific ideas and language into its National Disaster Housing Strategy and Plan.
Disrupted Education for Children with Disabilities
In NCD's 2006 The Impact of Hurricanes Katrina and Rita on People with Disabilities: A Look Back and Remaining Challenges paper, NCD noted that Hurricane Katrina displaced approximately 247,000 students from Louisiana, 125,000 from Mississippi, and 3,000 from Alabama; additionally, Hurricane Rita displaced about 86,000 students from Texas' schools. Over 200,000 school age children, 135,000 of whom are from Louisiana, have been rendered homeless because of Hurricanes Katrina and Rita. Some estimates indicate that 12 percent of the displaced students have disabilities. Advocacy, Inc., of Texas estimated that Hurricane Rita displaced about 2,200 children with disabilities under the age of five – many of those children will need early intervention services – and about 5,000 school-aged children with disabilities. One of the most crucial challenges for disaster recovery efforts is to continue the education of student-evacuees while rebuilding educational services in the Gulf Coast.
"Attendance at a school becomes an oasis of normalcy" for children who were traumatized by the hurricanes' devastation. However, after major disasters, many schools struggle to reopen for protracted periods of time. As a result, many student-evacuees integrate into new school systems. Nevertheless, the temporary nature of shelter or emergency housing has caused many students to be transferred from school to school numerous times.
For student-evacuees with disabilities, the transfer to other school systems has been particularly problematic. Some student-evacuees with disabilities were unable to register for school because they had not secured housing in the evacuation area and therefore could not provide documentation. However, the McKinney-Vento Homeless Assistance Act allows students to attend school despite the lack of formal documentation. However, for many student-evacuees with disabilities who did not bring documentation about the nature of their disability or about their IEPs when they fled from the hurricanes, some schools denied them the provision of necessary special education services.
The state of Alabama was an exception to this phenomenon. After Katrina, it decided to "take the parents at their word" and provided special education services to evacuees to the best of the schools' abilities, despite the lack of formal documentation. Similarly, Fort Worth district officials temporarily waived documentation requirements. Several Texas school districts hired additional staff in anticipation of an influx of students with special needs, estimating that between 10 and 15 percent of student-evacuees would have some type of learning disability. On a federal level, Congress and the President jump-started various efforts to help children with disabilities return to school as quickly as possible, releasing millions in aid to help displaced children.
The financial impact on people with disabilities who endure disasters is unknown, but it seems axiomatic that for low-income households, which are more prevalent among people with disabilities, the impact is considerable. Hurricane Katrina, though not the typical disaster, illustrates a number of problems. Because people with disabilities were displaced and relocated throughout the country, accessing specific services—such as Medicare and Medicare Part D prescription coverage, veterans' benefits, Social Security checks, and Supplemental Security Income (SSI)—was difficult, if not impossible in some instances. People experienced disruption of work and personal life, often the types of activities that give a sense of stability during stressful periods. People also lost access to their bank accounts to which monthly checks were being sent. The widespread displacement across the country meant that local, familiar social service and health care providers were not available. Case managers could not find their clients. The impact and extent of the disruption is not known, but it is clear that the effects were profound.
Medical and Health Impacts
An example of the profundity of the disruption is seen in one survey among those with one or more chronic conditions. Of those surveyed, 21 percent cut back or terminated their health care. Affected persons were usually elderly, uninsured, and/or isolated. Reasons for cutting back included the following: 41 percent lacked access to a physician; 33 percent could not afford or obtain medications; 29 percent had financial problems; and 23 percent lacked transportation to health care. The finding that these conditions affected seniors (disability prevalence increases dramatically with age) coincides with reports from caseworkers.
Other barriers to receiving health care and health problems for disaster victims include:
- Loss of medication or medical devices
- Finding time to seek medical care
- Paying for medical care
- New health problems
- Worsening health problems
When the health care infrastructure is itself affected, barriers and poor health outcomes escalate. For instance, following Hurricane Katrina, several medical centers and hospitals were forced to close or underwent extensive staff losses. As a result, one study reported the following health concerns among adults in New Orleans two years after the storm:
- More than 4 in 10 adults reported worse access to health care.
- In Orleans Parish, one in four adults reported being uninsured.
- Seventy percent of the uninsured were black.
- More than 1 in 10 adults ranked their health as fair or poor.
- Four in 10 said they had been diagnosed with a chronic disease
Considerable disruption to medications and mental health services occurred as a result of Katrina as well as in other disasters. After Hurricanes Ike and Gustav, for example, people remained away from their homes, providers, and pharmacies, and missed out on medications for weeks at a time. Under these circumstances, significant health problems can manifest from withdrawal symptoms or disrupted medication routines. Special needs shelters and other locations are increasingly addressing these concerns, but challenges remain at many shelter locations. Long-term studies of the consequences of these circumstances should be generated to better inform both policy and practice. Long-term and mobile outreach to affected, displaced populations needs to be further investigated.
A Holistic Approach to Recovery
With so many aspects of daily life profoundly affected in the aftermath of a disaster, recovering, rebuilding, and repairing damaged areas after a disaster requires a comprehensive plan, one that emphasizes a holistic mindset. A holistic approach promotes an understanding that—
- All parts of the community are interconnected. Homes connect to transportation routes that take people to work and back. Utilities supply power, water, and communication lines, the first two of which are critical for powering wheelchairs and refrigerating medications. Recovery planning requires that all parts of the community, including local residents, be considered and reconnected.
- Recovery must be sustainable, which means that recovery efforts should improve and protect local quality of life, economic opportunities, and environmental resources. Sustainable approaches require that social and intergenerational equity be incorporated into recovery. The best approach is a participatory process that brings people at risk into recovery efforts.
A holistic, sustainable recovery results in an improved environment for people with disabilities. Imagine the following possibilities when convening a recovery planning effort:
- Temporary housing is accessible and immediately available so that people with disabilities can reestablish household routines, assist their children with returning to school, go back to work, and begin rebuilding.
- Housing is not just rebuilt, it is rehabilitated communitywide to accessible levels through new codes and standards.
- Transportation routes are redesigned to provide wider pathways, auditory signaling systems at crosswalks, and Braille signage.
- Careful debris management reduces the overall effects of air pollution through proper burning and disposal. All workers are provided with protective equipment and monitored for a number of years thereafter.
- Recovery planning meetings involve people with disabilities as active participants. All public recovery meetings offer American Sign Language (ASL) interpreters, materials in Braille, and opportunities for people with cognitive disabilities to provide input as well.
- The rebuilt area features accessible sidewalks, businesses, recreational opportunities, and communitywide transportation options.
- New economic opportunities are recruited into the area to support people with disabilities. These opportunities may include grants to support new businesses, including social enterprises that support people with some kinds of cognitive or developmental disabilities.
- Geographic locations that have larger populations of people with disabilities (e.g., areas with senior care centers, state schools, assisted living facilities, naturally occurring retirement communities) get high priority for road clearance and utility restoration. Rebuilt utilities in these areas have top priority for underground placement of power lines (an expensive option but one that can save lives in an ice storm or other disaster).
- New mitigation efforts address risks experienced by people with disabilities. Mitigation measures that reduce those risks receive priority, such as bracing items that could fall and block exits from buildings, establishing new partnerships with organizations that support people with disabilities, designing preparedness materials that target those at risk, and providing insurance to those of limited means in high-risk areas.
- Workplaces incorporate features beyond the standard smoke alarm and first aid kit to include text and visual alert devices, evacuation devices, safety training, and buddy systems specifically for people with disabilities.
- The recovered community earns recognition as a place where all residents can return to living meaningful and productive lives at the same pace, regardless of disability.
- The burdens borne by people with disabilities in disaster (delays, lack of access, displacement) are reduced significantly before the next event.
To summarize, a holistic recovery is consistent with the livable community principles listed on the NCD website:
"Congress should adopt the principles embodied in Livable Communities to guide the provision of reconstruction funds, promoting a Gulf Coast that includes:
- Affordable, appropriate, accessible housing
- Accessible, affordable, reliable, safe transportation
- Physical environments adjusted for inclusiveness and accessibility
- Work, volunteer, and education opportunities
- Access to key health and support services
- Access to civic, cultural, social, and recreational activities."
Further, NCD makes the following policy recommendations:
- Individual Assistance program – The Individual Assistance program needs to specify that assistive devices and durable medical equipment can be included as qualified items. Specific examples of items that qualify should be included.
- National health care disasters strategy – Encourage the development of a national health care disaster strategy to provide long-term care (i.e., multiple years that span recovery) for individuals at low income levels.
- Accessible housing – All interim or permanent housing that is built or rebuilt/reconstructed should meet at least minimal accessibility requirements. Using universal design concepts when rebuilding communities benefits the general public as well as people with disabilities.
- Accessible housing – Financial or other assistance provided to individuals for disaster housing should include supplements to the standard housing assistance and support and funding for accommodations and retrofitting. This assistance may include SBA loans, FEMA grants, and USDA and HUD funding streams.
- Rebuilt infrastructure – Require that redesigned or rebuilt infrastructure offer more accessible features, such as wider pathways, auditory signaling systems, and tactile signage.
- Continuity of federal benefits programs – Develop federal mandates that programs such as Unemployment Insurance (UI), Disaster Individual Assistance (DIA), and Temporary Assistance to Needy Families (TANF) as well as those administered at the state level have strong emergency plans and continuity of operations plans in place.
Mitigation efforts represent the single best strategy to reduce the impacts of disasters. Mitigation reduces the risk that new disabilities will be created during disasters and enhances the survivability of those who currently have disabilities. Despite its powerful affect on outcomes following disasters, mitigation efforts appear to be minimal at best across the nation. Where they do exist, they often fail to address the needs of people with disabilities. Efforts to redress this situation require the involvement of voluntary organizations to encourage the mitigation of risk at the household level, as well as federal mandates to involve people with disabilities in mitigation planning, revision of guidance documents to increase accessibility in safe rooms, and funding to provide disability-specific mitigation measures.
Like everyone else, people with disabilities practice nonstructural mitigation when they acquire and follow checklists, create an emergency preparedness bag, and ensure that they have prepared for disaster to the best of their ability. However, there are a number of ways in which standard mitigation measures may not offer equal benefit to people with disabilities. For instance, although insurance is a commonly recommended nonstructural mitigation measure, given the lower income level of many seniors and some people with disabilities, buying enough insurance to cover all losses may not be possible. Further, insurance providers may require additional premiums for replacement of specific items, including specialized wheelchairs, TTYs, or other necessary equipment.
Structural mitigation occurs in the built environment. When the built environment is compromised in a disaster, it can block exits. Furniture may become an obstacle to negotiate or walls may shift, leaving exit doors difficult to open. The cables, insulation, and air-handling ducts normally hidden above the ceiling tiles may fall to the floor or remain partially suspended. These unanticipated obstacles greatly affect the ability of people with disabilities to safely exit the structure. Simple measures to secure freestanding furniture, cupboards, bookcases, and similar items can reduce the potential for injury and increase the potential for escape. Alternate escape plans must be developed and practiced to mitigate the effect of hurdles created when items fall and block egress.
In the workplace, individuals are protected from the effects of hazards, such as fire, by alarm systems. And while employers with alarm systems are required to have visual and audible alarms to ensure that everyone is alerted to the emergency, these mitigation measures are only helpful for people with disabilities if the accessibility requirements are enforced.
There are several possible points of intervention in the FEMA mitigation planning series that would heighten involvement of people with disabilities. Doing so would raise issues of concern, increase awareness, and build useful partnerships. Currently, the mitigation planning guides do not offer specific ideas for including or reaching out to people with disabilities. For example—
- Surveys and other tools could be used to assess the knowledge of specific groups, including people with disabilities, workplaces that employ people with disabilities, and organizations that provide support to this population. This task also identifies available resources that can be tapped, particularly employers and organizations. By surveying community members and those who link to people with disabilities, it is possible to identify barriers to mitigation planning within the disability community.
- Identify a mitigation "champion," recruited from within the disability community, providing a conduit and an advocate for information, insights, and communication both to and from people with disabilities.
- Specifically mention the disability community amongst the stakeholders for the planning team.
- Public engagement and community education must be open and accessible to all people. Locations for meetings must be required to be accessible and offer, for example, sign language interpretation and Braille materials. The guide recommends the use of instruments to gather information, such as questionnaires, but does not acknowledge a need for alternative formats. The public education campaign plan must include suggestions about making outreach materials accessible.
- Development of mission and vision statements must introduce a broadly inclusive consideration of all affected, including low-income, senior, and disability sectors of the community.
Additional FEMA guides elaborate on other elements of the mitigation planning effort, such as loss estimation, historical preservation, implementation, and assessment. Two strategies might be considered in future revisions of these documents: (1) integration of the suggestions listed above, and (2) creation of a stand-alone guide that provides specific means for including and reaching out to the disability community.
Avoiding disasters is preferable to responding to or recovering from them. Mitigation measures and planning that ensures the provision of a safer and better built environment for people with disabilities serves the entire population. Therefore, NCD recommends:
- Accessible mitigation materials – Upgrade the FEMA mitigation video series to current technologies and formats, such as downloadable videos. Expand the coverage beyond medical facilities to include congregate care facilities, schools, retirement communities, public housing, and individual housing. Specifically address the value of mitigation activities and measures with and for people with disabilities.
- Mitigation planning – Encourage FEMA review of local mitigation plans to assess them for the involvement of and impact on people with disabilities.
- Tax incentives – Provide tax incentives for businesses that provide accessible points of egress and for individuals who implement mitigation strategies in their homes.
- Funding – Support and fund long-term mitigation planning and community and state mitigation projects.
- Renovations and new construction – As schools are built, renovated, or substantially redesigned, require that the envelope be hardened according to the probable hazard (e.g. hurricane, tornado, ice storm, or earthquake) and that other measures be added to enable the facility to be used by the community as an accessible shelter. This includes matters involving power supply, the ability to hook up laundry equipment, and more restrooms.
Successfully addressing the needs of people with disabilities in times of disaster requires deliberate and thorough preparations that must include input in all disaster phase planning from people with disabilities. As self-advocating experts, people with disabilities offer invaluable knowledge of existing and potential barriers as well as creative and personal experience in overcoming them. Further, inclusion of people with disabilities throughout emergency phase planning promotes personal preemptive actions and enhances the credibility of emergency management personnel in times of actual emergency.
As mentioned at the start of the testimony, anyone at anytime can acquire a disability, particularly during emergencies. Furthermore, the challenges faced by persons with disabilities, seniors, and residents of low-income households in disaster-threat situations often demonstrate considerable overlap. People with disabilities should not be viewed as one more special interest group that drains resources from the common pool. Planning for and accommodating this large group often means being better equipped to serve all people.
On behalf of the Members of NCD, thank you again for the opportunity to contribute this testimony to the record.
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