FEMA's Assistance to Firefighters Grant Program: A Policy Implementation Analysis

U.S. Department of Homeland Security-

Federal Emergency Management Agency’s Assistance to Firefighters Grant Program:

A Policy Implementation Analysis

Craig Jeffries University of California, San Diego

Graduate School of International Relations and Pacific Studies

May 30, 2010

Craig Jeffries Policy Implementation Process A50038324 May 26, 2010

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1. Introduction

The focus of the following policy implementation analysis is to identify what public goods the

Federal Emergency Management Agency’s (FEMA) Assistance to Firefighters Grant (AFG) program

provides to its grant recipients, and how those goods relate to the broader operational mission of

national preparedness under the U.S. Department of Homeland Security (DHS). This analysis with be

conducted primarily by utilizing the management concept of the strategic triangle, which addresses a

program’s substantively valuable strategy, its political sustainability, and finally its operational

feasibility.1

The first section of this analysis will outline the origins of the AFG program, identify the type of

program using James Q. Wilson’s variants2; it will also identify the primary and external actors, and

finally the basic work-flow of the program. The second section will contemplate how the AFG program is

substantively valuable to FEMA’s overall goal of raising national preparedness levels; doing so by

discussing the cost and benefits associated with the grant program and explaining the role of state and

local funding obligations to first responders. The third section draws attention to the political

sustainability of the AFG program. In this section, the fairness of grant-giving is discussed, as well as the

day-to-day challenges facing FEMA officials when dealing with external stakeholders. Lastly, this section

will explain the role of private contractors and how their involvement can politicize the program. The

fourth section of this analysis focusing on AFG’s operational feasibility will first identify the operators,

managers and executives describing their interests, beliefs and culture. This section will also highlight

the program’s problems by identifying the “bugs in the system” that affect program implementation.

The fifth and final section lists the findings revealed in the analysis, concluding with a few

recommendations for making the program more effective, efficient and fair.

1For detailed discussion of the strategic triangle see Moore, Mark H., “Creating Public Value: Strategic Management in Government”, Harvard

University Press, 1995 pg. 70-71 2Wilson, James Q., “Bureaucracy”, Basic Books, 1989, pgs.158-171


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2. AFG: The purpose, the process and the actors

2.1 The Public Good and the Core Mission

The AFG program, also known as fire grants or the FIRE Act grant program, was established by

Title XVII of the FY2001 National Defense Authorization Act. The program, currently administered by the

Grant Programs Directorate (GPD) of FEMA, was established April 2007 in accordance with the post-

Katrina Emergency Management Reform act. This legislation consolidated all FEMA grant operations,

systems, training, policy and oversight.3 The overall mission of the AFG program is to support the

priorities of enhancing national capabilities of fire departments to protect both citizens and fire

personnel from fire-related deaths and injuries. Thus, in abstract this public good not only benefits its

primary users—the fire departments—but also its secondary users, the general public who are

protection from the devastations of fires. To do this, the AFG program provides federal grants directly to

local fire departments to help address a variety of equipment, training, and other firefighter-related

needs. AFG grants are allocated within the following areas: vehicle acquisition, operations and safety

and for regional projects.

2.2 Identifying the Type of Program

James Q. Wilson’s identifies four distinct types of government agencies that are useful in

explaining the management styles and overall policy implementation of public entities. He distinguishes

types of agencies by identifying whether outputs and outcomes are observable. In a production agency

both the outputs (what the agency does on a daily basis) and the outcomes (the overall effect of the

agency’s efforts) are observable. In a procedural agency only the outputs are observable, while

outcomes are not. In craft agencies outputs are not observed but outcomes can be seen. Finally, in

3 See “Strategic Plan FY2009-2011”, FEMA: Grants Program Directorate, October 2008


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coping agencies neither outputs nor outcomes are observed.4 While AFG’s outputs—application data

and reward totals—have been easily identifiable, outcomes have been difficult to document meaning

that the AFG program functions within a procedural agency. Consequently, ascertaining the overall

effectiveness of the program has been difficult.5 FEMA provide various metrics to legislative oversight

branches outlying where the funding has gone and for what purposes it has been allocated, as well as

the types of fire departments receiving the grants. Yet, these figures measure output, not outcomes.

2.3 Identifying the Primary and External Actors

The primary actors involved in the AFG program are its operators, AFG program officers and AFG

grants management specialists. The managers of the AFG program are the FEMA deputy administrator

for protection and national preparedness, and the assistant administrator for grant programs while the

executive is the FEMA administrator. Secondary actors involved in the AFG program are numerous and

dispersed but include: private contractors, congressional representatives, officials from the nine national

fire organizations6, and of course the nation’s fire departments applying AFG funding.

2.4 Brief Overview of Grants Process

Fire departments throughout the United States competitively apply for AFG funding each year,

and if successful, pass through the following three steps: 1) initial filtering of applications into funding

categories (vehicle acquisition, operations and safety or regional projects) to be scored by the grants

management system identifying competitive applicants; 2) independent panel peer reviews of the

competitive applicants; and 3) final agency decision-making taking into account the panel’s scoring and

recommendations, as well as statutory requirements. As of July 2009, FEMA received nearly 25,000 and

4 See the James Q. Wilson “Bureaucracy” (pgs. 158-172) for a full description of each agency classification.

5 Kunde, James et. Al, “Assistance to Firefighters Program: Accessing Performance”, A Report by the National Academy of Public Administration

for the U.S. Department of Homeland Security, April 2007 6 The nine national firefighter associations are: The International Association of Fire Chiefs, The International Association of Firefighters, The

National Volunteer Fire Council, The National Fire Protection Association, The National Association of State Fire Marshals, The International Association of Arson Investigators, International Society for Fire Service Instructors, The North American Fire Training Directors and The Congressional Fire Service Institute.


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22,000 applications for fiscal years 2008 and 2009 respectively, and awarded over 5,000 grants in each

fiscal year.7

3. Substantively Valuable Strategy

3.1 The Public Good

The federal government took a second look at the capabilities of the nation’s fire departments

after the events of September 11th. The heroic role in which firefighters and other first responders

where cast led the federal government and agencies such as FEMA to question whether they should be

doing more to help bolster the ability of these first responders to do their jobs. In 2005, Hurricane

Katrina furthered the federal government’s resolve in to play a bigger role in ensuring that firefighters

had adequate resources.

3.2 State/Local v. Federal Role Funding Obligations

Yet, many have questioned the appropriateness of the federal government via the AFG program

to subsidize local fire department’s routine operations. David Muhlhausen of the Heritage Foundation

believes that the vast majority of equipment purchased with AFG funds has traditionally been the

obligation of local governments.8 He stresses that with the program’s congressional reauthorization in

2009, and the subsequent lowering of the local funds match requirement—from 20 percent to 10

percent for departments serving more than 20,000 people, and from 10 to 5 percent for departments

serving less than 20,000—local governments will become even more dependent on federal aid.9 FEMA

counters this argument by suggesting that it is Washington’s job to step in and assist fire departments to

meet basic needs when local governments cannot, especially during economic downturns that

subsequently reduce tax revenues.10

7 For a more thorough breakdown of funding see “Fire Grants: FEMA Has Met Most Requirements for Awarding Fire Grants but Additional

Actions Would Improve Its Grant Process”, United States Government Accountability Office, October 2009. 8 Muhlhausen, David B., “Fire Grants: Reauthorization of an Ineffective Program”, October 20, 2009.

9 Ibid.

10 US GAO report, October 2009.


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3.3 Cost/Benefit Analysis of the AFG Program

But does AFG funding reduce fire-related deaths and injuries to firefighters and civilians? Again,

David Muhlhausen is critical of the federal program saying that in his analysis the program has no real

effect on overall fire safety. By comparing reporting figures to the National Fire Incident Reporting

System (NFIRS) of fire departments receiving AFG awards to those who had not, Muhlhausen concludes

that the AFG awards had no real effect on improving safety, as departments not receiving federal grants

did just as well at preventing fire-related death and injuries.11 Additionally, according to the U.S.

Government Accountability Office (GAO) there are 16 overlapping federal agencies that deal with first

responder issues12. Consequently, the AFG grants may not be a cost effective way of increasing local fire

department’s capabilities.

3.4 The National Preparedness Mission

Federal assistance to financially strapped fire departments is not the main justification for the

program’s existence, but rather its raison d’être is to ensure that the nation’s first responders are fully

prepared and equipped to respond to national emergencies such as natural disasters and terror attacks.

Thus, the program allows fire departments to purchase equipment needed to do this job. Such

equipment includes chemical and biological detection systems and interoperable communications

systems.13 Yet, after nearly a decade since the program’s inception most of what has been purchased by

award recipients is not specific to homeland security but rather basic firefighter equipment. A report by

the Brookings Institution argues that federal funding to firefighters should be directly linked to fighting

terrorism and not just general increases. For instance, training and equipment should only be funded if it

has compatible communications capabilities enabling first responders to better communicate and

11

Muhlhausen, David B., “Fire Grants: Reauthorization of an Ineffective Program”, October 20, 2009. 12

Edwards, Chris, “Downsizing the Federal Government”, Policy Analysis, no. 515, June 2, 2004. 13

Cordesman, Anthony H., “The New American Approach to Defense: The FY2003 Program”, Center for Strategic and International Studies,

February 6, 2002.


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coordinate with each other.14 With this in mind, DHS has been directed by congress to ensure that all its

efforts mutually support the overall goal of national preparedness. However, the AFG program’s

application selection process does not seem to have placed the necessary emphasis on this goal, as

applicants are selected and awarded based on financial need and the impact the award would have in

increasing the departments’ ability to serve the local community. Consideration of the award’s

contribution to overall national preparedness is secondary.15 A DHS-authorized study reviewing the AFG

program describes how the program contradicts DHS’ national preparedness mission declaring that “the

DHS National Preparedness Plan embodies one set of goals, aiming to strengthen preparedness for

terrorist attacks, major disasters, and other emergencies while the Fire Act embodies another set of

goals to reduce firefighter deaths and injuries, assist fire prevention efforts, and to reduce public deaths

and injuries”.16

4. Political Sustainability

4.1 Equity of the AFG Program

As the federal budget gets tighter and tighter year after year, all federal programs—including

the AFG program—are put up for review by congress, where their cost-effectiveness is assessed, as is

the overall value to the country. Placing the fate of the program in the hands of congressmen beholden

to special interests and a narrow set of constituents would seem to be a risky venture for those who

value the AFG program and respect its contributions. Yet, this is how the U.S. democratic system

functions. However, what if what is mandated by congress is unfair? For instance, the U.S. Senate is

widely seen as institution with disproportionate influence, as each of the 50 U.S. states has two senators

representing their interests. Thus, small states with minuscule populations like Wyoming and North

Dakota have the small voting power as big states like California and New York. This inequality becomes

14

Daadler, Ivo et. Al, “Assessing the Department of Homeland Security”, The Brookings Institution, July 2002. 15

Kunde, James, et. Al, “Assistance to Firefighters Program: Assessing Performance”, National Academy of Public Administration, April 2007. 16

Ibid. pg. 118


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dangerous when debating funding priorities related to homeland security and national preparedness.

States with bigger populations are at greater risk to terrorist attacks, and with more people, these areas

will suffer more from natural disasters. Unfortunately, the AFG program does not take into

consideration these types of risk factors to ensure that federal funds are dispersed in a fair manner,

reflecting the true needs of its applicants. Politics sadly is to blame for this deficiency.

Initially, AFG grants had a $750,000 cap placed on each award. What this meant was that the

amount of funding available to any given applicant was not a function of the service area’s size or the

threat-level it faced. Consequently, AFG grants did not buy much for big urban fire departments but

alternatively proved to be very valuable to smaller rural departments. This inequality appears to have

been recognized and addressed as the federal cap on awards was rescinded in 2004.17 Yet the

congressional debate over the program’s reauthorization reignited the competition for securing AFG

funds between career-urban/suburban departments and volunteer/rural departments. A 2009

Congressional Research Service’s (CRS) report states that the debate was heightened by the overall

reduction of AFG appropriation in fiscal year 2010, as well as the economic downturn in local

communities.18 Volunteer fire departments have been the largest recipients of AFG funds since the

program’s inception; however, the Fire Grants Reauthorization Act of 2009 seems to have ended

volunteer department’s dominance as it introduces a new framework for allocating AFG funds, now

requiring that 25 percent of all funds be made available to volunteer fire departments, 25 percent to

combination departments and 25 percent to urban departments.19

Aggregating the award money received by a state’s fire departments, it is clear that some states

win out at the expense of other states. One of the “winners” appears to be Pennsylvania, followed by

New York and California. Pennsylvania received $37.3 million in AFG awards or 6.6 percent of overall

17

Eisinger, Peter, “Imperfect Federalism: The Intergovernmental Partnership for Homeland Security”, Public Administration Review, vol.66,

no.4 (July-August 2006), pg. 539 18

“Assistance to Firefighters Program: Distribution of Fire Grant Funding”, Congressional Research Service, December 1, 2009 19

“H.R. 3791 Fire Grants Reauthorization Act of 2009”, November 18, 2009


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AFG funds in 2008. New York received $28.2 million or 5 percent of overall AFG funds in 2008. California

received $24.2 million or 4.3 percent of AFG funds. While these three largest recipients do not seem odd

due to their size and the generally high-level of vulnerability the state with the fourth largest share of

AFG funding in 2008 may raise some eyebrows. Alabama, with a population of just 4.7 million—about 13

percent of California’s population—received $22.3 million in AFG funds during fiscal year 2008.20 How

does one explain why Alabama with a population a fraction of the size of California and Texas is able to

obtain nearly as much as the former and more than the latter? The answer is most likely that Alabama’s

fire departments have done a very good job at mobilizing support from their political representatives in

Washington, who then push FEMA and AFG officials to consider their state’s AFG applications. External

politically pressure is not the only factor contributing to unfair grant distribution; internal political

considerations play an important role, as it is no coincidence that Pennsylvania ranks high in the overall

award totals year after year, as it is the home state of Tom Ridge, DHS’ first secretary.

4.2 Responding to External Stakeholders & the Inclinations of Particularistic Funding

The AFG program is unique from other federal grant programs in that it allows external actors a

large amount of influence on how and where federal funds are to be spent. There are four main external

stakeholders that affect how the program is implemented—doing so in very different ways and for

diverse motives. These stakeholders include: representatives in the U.S. Congress; officials from the nine

national fire associations; fire chiefs and firefighters in the nation’s fire departments applying for AFG

funding; and finally the private contracting personnel hired by DHS to assist with the implementation of

the program.

U.S. Congress: The U.S. Congress created the AFG program, mandating how it should be run and

allocating specific amounts of federal money for the program each year. It also serves in an oversight

20

Eisinger, Peter, “Imperfect Federalism: The Intergovernmental Partnership for Homeland Security”, Public Administration Review, vol.66,

no.4 (July-August 2006), pg. 539


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capacity, monitoring the program’s progress in committee hearings as well as commissioning studies

reviewing its effectiveness. In creating the program congress limited FEMA’s grant-making discretion to

ensure that the AFG program leveraged rather than supplant local financial funding of basic firefighting

needs. Specifically, the congressional statute mandates that grants should not be awarded to

departments who are not regularly funding by local governments or if FEMA determines that local

budgetary allocations will be supplanted as a result of the AFG award.21

On the micro level, congressional representatives announce AFG grant awards to their

constituents. While at first glance this role may seem routine and noncontroversial; however, some

point out the wide-area for political manipulation of announcing grant awards. For example, Theodore

Anagnoson, writing in the American Journal of Political Science argues that some politicians announce

grant awards in crucial states just before an election enabling them to secure votes from key

constituents.22 As most citizens maintain a great respect for firefighters and believe that federal funding

to them is a legitimate use of the public’s resources, it seems logical that members of congress would

want to announce grant awards in order to win political capital.

National Fire Associations: Officials from the nine national fire associations play two critical roles within

the AFG program: 1) their members serve as peer reviewers during the second stage of the AFG

selection process; and 2) their professional opinion is sought by FEMA, with their inputs being

incorporated into AFG’s annual program guidance. During the independent panel review stage panelists

are supposed to use their technical knowledge fairly and impartially to judge the merits of each

department’s application. Yet there is room for bias, as officials may score certain departments higher

because of department type (e.g. volunteer) or service area (e.g. rural). The fire associations have a

more explicit role in shaping the AFG program, as they are asked to provide recommendations on key

21

Kunde, James, et. Al, “Assistance to Firefighters Program: Assessing Performance”, National Academy of Public Administration, April 2007. 22

Anagnoson, J. Theodore, “Federal Grant Agencies and Congressional Election Campaigns”, American Journal of Political Science, vol. 26, no, 3

(August 1982), pp. 547-561


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priorities for funding to be included in the program guidance each year. While these views do not

represent the final say, they do prove to be powerful voice having a significant impact on the direction

of the AFG program.

AFG Applicants: In the era of reinvented government, AFG applicants are viewed as customers, with

AFG operators at FEMA clearly attempting to provide them with quality customer service. Examples of

this focus are the user-friendly program website and e-grants system with an online tutorial, as well as

the numerous AFG workshops held throughout the country. In addition, the AFG program maintains

regional support centers, a national helpline to assist applicants at all stages of the grant-cycle, and

finally a mentoring program, where current applicants are paired with former peer review panelists.

Private Contractors: FEMA employs private contractors to assist in the implementation and evaluation

of its grant programs. The AFG program is no exception. Private contractors seem to function in the

government by network role espoused by Elaine Kamarck with FEMA outsourcing its work to contractors

from firms such as Booz Allen Hamilton and SAIC. 23 Some of these contractors—the author included—

worked alongside operators, while others work with managers in developing grant guidance and

performance reviews. The former are usually embedded inside the grants management section of the

AFG program working with FEMA grants management specialists. The tasks of these contractors varied

ranging from administering a grant’s ongoing performance, assisting in the closeout process and

reviewing the grant performance of past grantees. Consequently, the scope for shaping policy by private

contractors working on this side of the program was quite limited. Conversely, contractors assigned to

the programmatic side were solicited for their views and often had them incorporated into program

guidance, thus giving them a greater opportunity to influence the program.

5. Operational Feasibility

23

For a detailed discussion of “government by network” see Kamarck, Elaine, “End of Government…as we know it”, chapter 6


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5.1 Operators, Managers and Executives: Functions, Interests and Beliefs

Operators: The rank-and-file operators working inside the AFG program are program specialists and

grants management specialists (GMS). The former deploy programmatic guidance for the grant program

as a whole dictating the standard operating procedures to applicants, awardees and grant

administrators. Many of these program specialists are indeed “special” as they are experts in certain

fire-related aspects. Thus, their knowledge is highly-valued by managers inside the program offices of

FEMA’s grants division. They also maintain a good rapport with AFG applicants and officials from the

nine national fire associations who they meet at regional AFG conferences and workshops. Program

specialists are also called upon to examine and score AFG applicants’ grant proposals paying particular

attention on the merits of the mission and overall usages of the grant. While AFG program specialists

spend most of their time analyzing the qualitative elements of an applicant’s grant proposal, grants

management specialists pay more attention to its financial aspects. GMS examine the financial feasibility

of the department, specifically whether or not the department intends to meet the local funding match,

whether or not the local government is currently allocating public funds to the department, and

whether the applicant is receiving other federal funding so as to avoid duplication. In addition, GMS

carefully monitor the grantee performance, auditing the financial records of departments to ensure that

federal funds are being spent wisely and pursuant to the award agreement.

These two sets of operators coordinate on many different levels. At one level, GMS may contact

programmatic staff to relay concerns that grantees have raised. GMS may also seek approval from

programmatic staff concerning specific equipment requested by a grantee in an award amendment. On

the other hand, programmatic staff will check with GMS to verify if proposals for new equipment are

financially reasonable given the grantee’s financial need. In reviewing grantee performance, both GMS

and program staff conduct desk reviews of departments who have received federal funds. Usually, the

program staff will conduct reviews of departments that have been singled out by managers, executives


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or even congressional representatives. However, a desk review conducted by a programmatic staff

member or a GMS is conducted in the same manner, analyzing the same areas of performance. In fact,

the template used in both reviews is identical. Yet, reviewer comments appear to address different

aspects. For example, programmatic staff may want more information regarding the overall

effectiveness of equipment purchased with the grant money, while GMS comments tend to more

focused on financial reporting and cost-benefit analysis. In addition to desk reviews, on-site audits are

conducted throughout the year and are chosen at random—yet some departments are pre-selected due

to congressional urging or because they received a high award amount. On-site audits require that there

be one GMS and one programmatic specialist, and that both sign off on the review.

While both types of operators perform valued functions in the implementation of the program it

is hard not to notice that AFG applicants seem to respect the programmatic staff more than the GMS, as

they view the program specialists as experts in the field of fire-safety who understand the needs and

duties of firefighters. While fire departments typically view GMS staff as representing the average

paper-pushing Washington bureaucrat who is overly concerned with rules and regulations.

Managers: Managers of the AFG program are FEMA deputy administrator for protection and national

preparedness and the assistant administrator for grant programs. The current FEMA deputy

administrator for protection and national preparedness is Timothy Manning, whose role is to prepare

the nation to protect against, prevent, respond to, and recover from acts of terrorism and natural

disasters. He coordinates the efforts of the four directorates including: the National Preparedness

Directorate, Grant Programs Directorate, Office of National Capital Region Coordination and National

Continuity Programs Directorate to ensure that the country’s national preparedness goals are met.24

Mr. Manning—a former firefighter—has been seen as strong advocate of the AFG program, evidenced

24

See biography of Timothy W. Manning at http://www.fema.gov/about/bios/tmanning.shtm

http://www.fema.gov/about/bios/tmanning.shtm


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by his congressional testimony in 2009 to reauthorize the program.25 Under Mr. Manning is Elizabeth

Harman who is the assistant administrator for grants programs and the head of the GPD. Confirmed by

the U.S. Senate in March 2010, Ms. Harman is responsible for the administration, implementation,

awarding, and closeout of more than 50 different disaster and non-disaster grant and financial

assistance programs, which amount to approximately $4 billion in non-disaster grant funding annually.26

Like Mr. Manning her background is in the firefighting profession where she was both a volunteer and

career firefighter. Additionally, Ms. Harman served as the director of hazardous materials and weapons

of mass destruction training department at the International Association of Firefighters. Having two

managers possessing firefighting backgrounds bodes well for the program’s survival, and also gives the

program a perception of professionalism.

While these two managers have different day-to-day tasks it is clear that both want the AFG

program to succeed. Yet, both managers’ responsibilities extend far behind just running the AFG

program. In the case of Mr. Manning he must respond to the demands of both the FEMA and DHS

heads, as well as congressional representatives pushing for results in achieving the national

preparedness goals. Yet, the AFG program’s goals are quite different from the national preparedness

goals, and to achieve the former sometimes means going against the latter. Ms. Harman’s dilemma is

not two conflicting priorities but rather the scale of grant programs that she must oversee. With so

many disparate grant programs under her watch it is hard for her to spent much time on any one

program. Thus, she must delegate day-to-day managerial authority to her operators. Knowing that AFG

is best classified as a procedural program where outputs are observable but outcomes are not,

managers must therefore rely on standard operating procedures (SOPs) to maintain control over the

25

“Statement of Timothy W. Manning to the U.S. House Committee on Science and Technology, Subcommittee on Technology and Innovation”, July 8, 2009, accessed at http://www.fema.gov/pdf/about/testimony/070809_manning.pdf 26

See biography of Elizabeth M. Harman at http://www.fema.gov/about/bios/eharman.shtm

http://www.fema.gov/pdf/about/testimony/070809_manning.pdf

http://www.fema.gov/about/bios/eharman.shtm


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program and to feel confident that their subordinates are not abusing their positions in the absence of

everyday oversight. These SOPs outline how each of the operators is supposed to perform their jobs: for

GMS, SOPs dictate how they are to conduct financial reviews, award negotiations, formulate risk

methodology to support grant allocations and how to disperse funds. For program specialists, SOPs

inform them how to provide subject matter expertise, respond to regional office and stakeholder

inquiries and develop grant guidance materials.

Executives: FEMA administrator W. Craig Fugate is the executive of the AFG program. Like his

subordinates Mr. Manning and Ms. Harman, Mr. Fugate also has a background as a firefighter. Even

though he is a political appointee, Mr. Fugate’s resume indicates that he possesses a long history of

public service within the emergency management sector.27 Thus, Mr. Fugate’s benefits greatly by the

perception that he is focused on running the agency in a non-partisan and professional way; very much

unlike the previous FEMA head Michael Brown, appointed by President George W. Bush because of his

political loyalty and not his qualifications for the post. With Mr. Fugate’s reputation for professionalism

and dedication to the fire service profession, he will likely command great respect from his subordinates

in FEMA, members of congress, as well as those in the firefighter community who all seek to work with

him on establishing the goals and priorities of the AFG program.

5.2 The Program’s Implementation

Operationally, the review process for the AFG grant program proceeds in three evaluation

phases: 1) an automated scoring process, which acts a prescreen determining an applicant’s eligibility

and the alignment of the proposed award to the grant program’s overall funding priorities; 2) successful

applications from the first round are then sent to an independent peer review panel where officials from

27

Biography of William Craig Fugate, accessed at http://www.fema.gov/about/bios/wfugate.shtm

http://www.fema.gov/about/bios/wfugate.shtm


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the fire service community evaluate and score applications individually according to several factors

agreed to by the nine national fire associations and FEMA officials working within the AFG program; and

3) a final technical review conducted by subject matter specialists, FEMA officials from the AFG program

office and grants management divisions.28

Because the AFG program does not have the resources to review all applications by hand, the

first phase is meant to cut down the number of applications, which on average are about 20,000 for any

given year. Applications will the highest scores move on to the panel review phase. The median

threshold for those applications that make it to this next phase is the point when the total requested

dollar amount equals exactly 200 percent of that fiscal year’s federal budget allocation to the program.29

During the peer-review panel stage reviewers—officials from the nine national fire associations—score

the applications in four areas: 1) project description; 2) cost-benefit of the proposed project; 3) the

financial need of the applicant; and 4) the effect of the proposed project on daily operations.30 After the

peer-review evaluations are conducted and entered into FEMA’s electronic database, an average score

is calculated determining whether an application proceeds to the final technical review phase. In the

final phase, a group of subject matter specialists review each application—along with the attached peer

review comments—ensuring the technically feasibility of the proposed project. These subject experts

also suggest potential modifications to the grant proposal that they feel could strengthen the

effectiveness of the federal funds.

If an application passes through all stages of the selection process it is sent to the AFG program

office for a final review to ensure that its proposals meet both the statutory requirements mandated by

congress as well as the program guidance dictated by FEMA’s GPD. After this review, the application is

28

See the U.S. Government Accountability Office’s report (2009, p. 57) for a more detailed walkthrough of the AFG evaluation process. 29

Ibid. 30

See the U.S. Government Accountability Office’s report (2009, p. 58) for a more detailed walkthrough of the AFG evaluation process.


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sent to the GMS division where the application’s financial information is reviewed. After this process is

completed the application is deemed worthy of federal funding and the GMS will obligate funds to the

fire department. The grantee then receives a notification of the award, as well as the grant package

outlining the requirements agreed to by both parties.31

5.3 Identifying the “Bugs in the System”

Utilizing James Pinkerton “bureaucratic bugs in the system” critique of public bureaucracy we

can address the problems with the implementing the AFG program.32 While Pinkerton lists five “bugs”,

only one seems appropriately fitting to the AFG program, namely, Olsonism or the accretion of special

interests leading to economic inefficiencies and wasteful lobbying. The critics of the AFG program

including those cited in this analysis (Veronique de Rugy, David Muhlhausen and Chris Edwards) point

out that the AFG program is just another way for members of congress to distribute political rents to key

constituents making them dependent on federal aid to finance operations that used to be the sole

obligation of local and state governments. This problem is compounded by the fact that FEMA does not

identify and address redundancies of grant awarding. For example, Veronique de Rugy writes that 132

federal grants go to state emergency management agencies, fire marshals and fire departments all

addressing fire-related needs. Additionally, she points out that these grants are administered by up to

six federal agencies including FEMA.33 The Office of the Inspector General’s report on the efficacy of DHS

grant programs echoes this point saying that many of the DHS’s grant programs are not efficient

because they require DHS and FEMA officials to waste time and resources performing redundant

services on various grant programs. Another problem is the uncertainty felt by external stakeholders

over when each year’s program guidance will be released. When guidance is delayed the whole grant

31

Usually, as noted earlier, the fire department’s congressional representatives will be the first to inform the awardee. 32

Pinkerton, James P., “What Comes Next: The End of Big Government and the New Paradigm Ahead”, New York: Hyperion, 1995). 33

Veronique de Rugy, “What Does Homeland Security Spending Buy?”, American Enterprise Institute, AEI Working Paper #107, October 29,

2004


18

process is also delayed that impacts applicants because they are then unsure if they can secure the

required local match funds from their local governments.34

6. Findings and Recommendations

6.1 Effectiveness, Efficiency and Fairness

Effectiveness: Critics argue that the AFG program has failed in its mission to reduce fire-related deaths

and injuries pointing to statistical analysis showing no clear difference in NFIRS reporting for AFG award

recipient departments over non-recipient departments, as well as no significant improvement over time

for AFG recipient departments.35

Efficiency: DHS and FEMA’s development of separate grant programs promotes fragmentation and

makes coordination near impossible at both the state and federal levels. Because of deficiencies in the

evaluation of the grant award’s effectiveness, it is still hard to measure whether an AFG award leverages

or supplants local, state and other federal aid. Yet, others attributed the success of the AFG program to

its direct engagement with officials from the national fire service organizations who set priorities and

judge the quality of each of the AFG applications each year, a successful government by network

partnership.36

Fairness: While the old bias toward funding small rural volunteer fire departments has been rectified by

a congressional statute in the 2009 reauthorization of the program, smaller states with much less risk

are still receiving a disproportionate share of AFG funding due to intense political lobbying on the part of

rural volunteer fire departments located in small U.S. states, and the willingness of congressional

representatives to distribute particularistic funding in order to ensure political support come election

time.

34

“Fire Grants: FEMA Has Met Most Requirements for Awarding Fire Grants but Additional Actions Would Improve Its Grant Process”, United

States Government Accountability Office, October 2009 35

David Muhlhausen, “Fire Grants: Reauthorization of an Ineffective Program”, The Heritage Foundation, October 20, 2009 36

James Kunde, et. Al, “Assistance to Firefighters Program: Assessing Performance”, National Academy of Public Administration, April 2007


19

6.2 Key Findings and Recommendations

Findings: Although the program’s operational sustainability appears quite robust and its political

sustainability seems ensured, AFG’s substantively valuable strategy emerges as the weakest link in the

strategic triangle. Even while operators and managers in the AFG program have administered the

program quite well and its executive has been similarly effective at maintaining political support for the

program, the glaring flaw remains as to be whether delivering federal funds to subsidize the routine

operations of local fire departments is a legitimate use of the public funds or even the obligation of the

federal government.

Additionally, being a procedural program, AFG program’s outcomes are not observable, thus

efforts to quantify its effectiveness are hard to obtain. Many commentators point out this failing as one

of the program’s biggest problems, making it vulnerable when it comes up for reauthorization in

congress. For example, the 30 percent drop in federal appropriations for the program is attributed to a

Heritage Foundation study suggesting that the program did not make the areas served by AFG fire

departments safer, thus pointing to the program’s ineffectiveness. While it is difficult to analyze how

well the AFG program has done in reducing the risk of fire-related deaths and injuries to firefighters and

civilians, it is clear that the AFG program has somewhat indirectly spurn the growth of state and local

spending on fire-related activities. For example, in fiscal year 2004 AFG funding totaled $675 million,

while local government expenditures on firefighting activities exceeded more than $28 billion.37 The AFG

program remains a competitive grant program that does not compel departments to apply and is not

intended to regulate local fire departments. Yet, the program does offer an opportunity for the federal

government via DHS and FEMA to leverage AFG funds in order to implicitly shift local priorities toward

federal ones, specifically toward the national preparedness goals.

37

James Kunde, et. Al, “Assistance to Firefighters Program: Assessing Performance”, National Academy of Public Administration, April 2007


20

Recommendations: If the program’s supporters want to continue the program they must gather the

necessary evidence to prove the program’s effectiveness. Some recommendations to do so are: 1) to

incorporate community risk assessments into award selection criteria to strive to have a greater impact

of reducing fire-related incidents; 2) make revisions to the closeout questionnaire award recipients are

required to complete to include questions that focus on the outcomes initially highlighted in the grant

proposal; and 3) to publish best practices based on success stories from past grantees that highlight the

effectiveness of AFG funding in increasing the department’s capabilities to address issues related to the

national preparedness goals outlined by DHS.


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Sources of Reference

Anagnoson, J. Theodore, “Federal Grant Agencies and Congressional Election Campaigns”, American Journal of Political Science, vol. 26, no.3 (August 1982), pp. 547-561 “Assistance to Firefighters Program: Distribution of Fire Grant Funding”, Congressional Research Service, December 1, 2009 “Biography of Timothy W. Manning, Deputy Adiminister, Protection and National Preparedness”, http://www.fema.gov/about/bios/tmanning.shtm Cordesman, Anthony H., “The New American Approach to Defense: The FY2003 Program”, Center for Strategic International Studies, February 6, 2002 Daalder, Ivo, I.M. Destler, James Lindsay, Paul Light, Robert Litan, Michael O’Hanlon, Peter Orszag and James Steiberg, “Accessing the Department of Homeland Security”, The Brookings Institution, July 2002 de Rugy, Veronique, “What Does Homeland Security Spending Buy?”, American Enterprise Institute, AEI Working Paper #107, October 2004 Edwards, Chris, “Downsizing the Federal Government”, Cato Institute: Policy Analysis, no. 515 (June 2, 2004), pp. 1-62 “Efficacy of DHS Grant Programs”, Office of the Inspector General, U.S. Department of Homeland Security, March 2010 Eisinger, Peter, “Imperfect Federalism: The Intergovernmental Partnership for Homeland Security”, Public Administration Review, vol. 66, no. 4 (July/August 2006), pp. 537-545 Kunde, James, Paul Brooks, Glenn Corbett, Harry Hatry, Bruce McDowell and Daniel Stephens, “Assistance to Firefighters Program: Assessing Performance”, National Academy of Public Administration, April 2007 “FEMA Grants Briefing”, FEMA Region III, United States Department of Homeland Security, September 29, 2009 “Fire Grants: FEMA Has Met Most Requirements for Awarding Fire Grants but Additional Actions Would Improve Its Grant Process”, United States Government Accountability Office, October 2009 “H.R. 3791 Fire Grants Reauthorization Act of 2009”, United States House of Representatives, November 18, 2009, accessed at http://www.gop.gov/bill/111/1/hr3791

http://www.fema.gov/about/bios/tmanning.shtm

http://www.gop.gov/bill/111/1/hr3791


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Moore, Mark H., “Creating Public Value: Strategic Management in Government”, pg. 70-71 Muhlhausen, David B., “Fire Grants: Reauthorization of an Ineffective Program”, October 20, 2009 “Strategic Plan FY2009-FY2011”, FEMA: Grants Program Directorate, October 2008 Wilson, James Q., “Bureaucracy”, Basic Books, 1989, pgs.158-171

FEMA's Assistance to Firefighters Grant Program: A Policy Implementation Analysis

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