WASHINGTON — Homeland Security Secretary Kristi Noem directed the Federal Emergency Management Agency to prepare a memo on how to abolish itself and create a re-branded, radically smaller disaster response organization, according to a copy of the document reviewed by Bloomberg News.

As recently as last week, President Donald Trump and Noem said they wanted to wind down FEMA but offered few details publicly. The March 25 memo offers insight into how the administration has weighed which of its current functions to cut. Technically, only Congress can eliminate the agency.

Titled “Abolishing FEMA,” the memo was addressed from then-acting FEMA head Cameron Hamilton to his bosses at the Department of Homeland Security and outlines a number of functions that “should be drastically reformed, transferred to another agency, or abolished in their entirety,” possibly as soon as late 2025. Potential changes included eliminating long-term housing assistance for disaster survivors, halting enrollments in the National Flood Insurance Program and providing smaller amounts of aid for fewer incidents — moves that by design would dramatically limit the federal government’s role in disaster response.

The existence of the seven-page memo has not been previously reported. While Trump and other officials have continued to press for abolishing FEMA in its current form since the memo was created, it’s unclear which specific recommendations from the document are still on the table.

“This just means you should not expect to see FEMA on the ground unless it’s 9/11, Katrina, Superstorm Sandy,” said Carrie Speranza, who used to advise the agency and is now president of the US council of the International Association of Emergency Managers.

DHS, FEMA, and the White House did not respond directly to questions about the memo’s creation, contents, or how it has been used since. Instead, DHS Assistant Secretary for Public Affairs Tricia McLaughlin wrote in an email: “It’s not a secret that under Secretary Noem and Acting Administrator Richardson, FEMA, as it is today, will no longer exist. Federal Emergency Management will shift from bloated, DC-centric dead weight to a lean, deployable disaster force that empowers state actors to provide relief for their citizens. The old processes are being replaced because they failed Americans in real emergencies for decades.” Former FEMA leader Hamilton did not respond to requests for comment.

FEMA, which was created by President Jimmy Carter in 1979, has come under attack from both Democrats and Republicans for a range of issues — from its struggle to provide timely assistance in the wake of deadly hurricanes, such as Katrina and Maria, to its rebuilding programs, which have faced mounting costs as climate change drives increasingly damaging weather in densely populated communities.

A number of new reform bills have surfaced in Congress, including a proposal by Louisiana Republican Clay Higgins to replace FEMA with block grants to state governments similar to some social safety-net programs, with the goal of reducing costs. Competing bipartisan bills suggest leaving FEMA intact while overhauling its grant programs and reimbursements in an effort to speed up the recovery process.

The memo, meanwhile, outlines numerous ways to drive down federal disaster spending, largely by canceling long-running initiatives, revoking financial assistance altogether in some cases and pushing more disaster oversight and funding onto state and local governments. Many of these proposals appeared in the Heritage Foundation-led Project 2025 report — though its authors recommended keeping FEMA intact. Disaster experts, including ex-FEMA officials, say the plans would overwhelm state budgets and lead to longer recoveries, especially if carried out on a fast timeline.

‘A smaller footprint’

The memo came after Noem directed staff to draw up plans for reducing the agency to “a smaller footprint of core functions,” according to the document. Hamilton wrote it in coordination with a small number of veteran senior FEMA officials, according to people familiar with the matter who weren’t authorized to speak publicly.

Hamilton outlined a new agency that would still play a central role in preparing for and immediately responding to disasters, but would ratchet back everything else.

To begin with, he recommended that the federal government cease assistance for smaller, less destructive events and focus resources on “disasters of national significance.” Under the new framework, states would likely have to pay a greater share of associated costs than they commonly do now.

Michael Coen, who served as FEMA chief of staff under President Joe Biden, said the proposed approach could “leave a lot of communities behind” since many states don’t have the budget or capacity to help communities fully recover. “If you live in a community in Vermont that is affected by a flood, that’s a significant event for you, but it might not be a significant event for national security,” Coen said.

For bigger disasters, the memo suggests the federal government oversee search-and-rescue teams and logistics tied to stockpiling water, food and other critical resources, and provide some financial relief right after a disaster. These functions “would be neither effective or efficient to replicate 50 times over at the state level,” per the memo.

But even for these bigger events, Hamilton recommended a narrower federal role for long-term recovery. For example, the memo proposes FEMA no longer provide housing for disaster survivors due to high costs. This would mean eliminating long-term rental assistance and direct housing for disaster survivors, including government-leased apartments or FEMA trailers or RVs.

Coen questioned how such a sweeping reform would work in practice. “States don’t have the capacity to administer their own housing programs for disaster survivors,” he said.

The document acknowledges that most states are today “unprepared” to step up their role. Hamilton proposed initially providing “robust” support for growing state and local capacity — such as some grants, training and exercises — that would later be ramped down.

The memo is also critical of the National Flood Insurance Program, which has more than 4 million policyholders currently enrolled, for pushing the government “farther and farther into debt.” NFIP has filled a gap in the insurance market since 1968, providing subsidized flood coverage for homeowners. But as climate change increases flood risk, the program has become insolvent. Hamilton suggested Trump may “be able to direct the cessation of new policy sales and renewals,” but that more research was needed into the president’s legal options for ordering reforms.

At the end of the memo, Hamilton proposed four possible new names for FEMA: the Office of Crisis Management (OCM), the Office of Crisis Response (OCR), the National Crisis Response Agency (NCRA) and the National Office of Emergency Management (NOEM) — an acronym that dovetails with the name of the Homeland Security secretary.

Executive branch powers, limits

Hamilton exited the agency in May, a day after testifying before Congress that he thought FEMA shouldn’t be abolished. He was replaced by Homeland Security official David Richardson, who has limited disaster management experience.

Many of the proposed changes cannot be implemented “without the engagement and action of Congress,” according to the memo. For example, permanent changes to types or amounts of housing and other forms of individual assistance would likely require legislative action, as would reforming or repealing the flood insurance program.

But staff deemed the executive branch could roll out others immediately, such as by scaling back aid for disasters. In April, FEMA ended a grant program funding projects to reduce future disaster damage by making communities more resilient; this is one of the programs identified for possible elimination in the memo.

A FEMA Review Council established by Trump via executive order met for the first time in May and is set to produce a report with recommendations for reforming the agency in November. Given the administration’s urgency around overhauling FEMA, Hamilton had recommended skipping that process and canceling the council.

Last week, both Noem and Trump reiterated their intention to ax the agency after the end of this hurricane season. “Under Secretary Noem’s leadership, the FEMA Review Council is developing a comprehensive plan for necessary change,” said McLaughlin of DHS. Climate costs are increasingly high. The U.S. spent nearly $1 trillion on disaster recovery and other climate-related needs over the 12 months ending May 1, according to an analysis by Bloomberg Intelligence.

The big question now is if “a significant earthquake or a hurricane in the coming months” could shift the conversations around FEMA once more, said Coen. “We’ll see.”

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