Letter to FEMA requesting registration extension for Puerto Ricans

Mr. John Rabin
Acting Regional Administrator
FEMA Region II
26 Federal Plaza, Suite 1307
New York, NY 10278-0001

Re:       Request for an Extension of Time to Request FEMA Benefits

Dear Mr. Long and Mr. Rabin,

On behalf of the New York City Bar Association, we join the Government of Puerto Rico’s request to extend the time for individuals impacted by Hurricane María to register for FEMA’s federal assistance to individuals and households pursuant to 44 CFR 206.112.

While the standard FEMA registration period is 60 days following the date of the disaster declaration, the impact of the hurricane that devastated Puerto Rico on September 20, 2017 is anything but standard.  Until recently, the majority of the American citizens living in Puerto Rico did not have running water, electricity or telecommunications.  As of today, nearly 60% of the Island’s residents remain without electricity and only 47.2% of cell sites are operational.[1]  While many individuals have been able to register for assistance – FEMA reports that approximately 800,000 have registered[2] – we can surmise that many more have not given the current conditions on the Island.  Although there are groups on the ground such as Ayuda Legal Huracán María providing legal assistance as quickly as possible through the use of volunteers traveling to sites around the Island, the obstacles to reaching all affected residents are significant.  Much more needs to be done, and more time is necessary to accomplish this task.

FEMA itself understands the challenges faced by the residents of Puerto Rico:  it has extended Puerto Rico’s deadline for Disaster Unemployment Assistance to January 11, 2018 and it has granted Temporary Shelter Assistance until January 13, 2018.  While some FEMA Disaster Recovery Centers have previously opened in certain parts of the Island, some only just recently opened, on November 7, in Bayamón, Manatí, Naranjito, Orocovis.[3]

We understand that after the standard or extended registration period ends, FEMA may accept late registrations for an additional 60 days for registrants who provide suitable documentation to support and justify the reason for the delay in their registration.  However, in light of the catastrophic disaster at issue, the City Bar respectfully requests that the standard registration be extended for an additional 120 days so as to avoid the need to justify the reason for the delay.  In our view, the reason for the delay is self-evident and the administrative burden of determining which reasons are “justified” seems to be a wholly unnecessary use of resources.

Extension of FEMA deadlines to register for federal assistance is not unprecedented and we urge you to exercise that discretion under these extraordinary circumstances.

Thank you for your attention to this important matter.

Respectfully yours,

John S. Kiernan
President, New York City Bar Association

Roger Juan Maldonado
Chair, New York City Bar Association
Task Force on Puerto Rico

CC:

Hon. Jose M. Serrano

Hon. Nydia M. Velázquez