duplication of benefits. See 44 C.F.R. 206.191. The sequence of delivery for major forms of assistance is as follows:
1. Volunteer agencies’ emergency assistance (e.g., American Red Cross emergency shelters) and insurance (including flood insurance).
2. Housing assistance pursuant to section 408 of the Stafford Act, i.e., FEMA grants for rental assistance, home repair, or home replacement.
3. Small Business Administration and Farmers Home Administration disaster loans; 4. ONA, pursuant to section 408 of the Stafford Act, to replace necessary personal items like basic clothing, furniture and appliances, transportation, medical, dental, and funeral expenses.
5. Volunteer agencies’ “additional assistance” programs. 6. The “Cora Brown Fund,” used for disaster victims who have exhausted all avenues of assistance, but who still have unmet needs. FEMA uses these funds under the authority of 42 U.S.C. § 5201(b) of the Stafford Act and 44 CFR 206.181.
However, insured applicants may be able to obtain assistance when payment of
benefits are being significantly delayed through no fault of the applicant, benefits are exhausted, or benefits are insufficient to cover the housing or other needs. For example, a homeowner insured for property loss may not have coverage for alternative housing. In such a case, the homeowner may be eligible for rental assistance if her damaged property is uninhabitable while repairs are being made.
Types of Losses Covered by IHP IHP only covers repairs or replacement of real or personal property that was
damaged as a direct result of the disaster and that is not covered by insurance. Repair or replacement will not improve the home beyond its pre-disaster condition, and is unlikely to bring it up to par with its pre-disaster condition, unless the improvements are required by the Vermont Fire & Building Safety Code or other applicable building codes.
Housing needs under IHP consist of housing repair, housing replacement, and
rental assistance. Replacement is rare. In Vermont, replacement grants were awarded to mobile home owners whose houses were destroyed by Irene only after close to a year of struggling with FEMA. Housing repair grants are significantly more likely to be offered than housing replacement grants. IHP funds are limited to making the applicant’s home safe and sanitary, not making the home the same as it was prior to the disaster. Funding may be issued to cover the following types of repairs:
Structural repairs, e.g., foundation, walls, roof, floors. Windows and doors. Kitchen basics (cabinets). Septic or sewage system. Well or other water system. Utilities (electrical, plumbing, gas, etc.).
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