FEMA’s National Advisory Council (NAC) issued its annual report for 2022, finding FEMA should “prioritize equity impacts associated with the [Benefit Cost Analysis (BCA)]”, noting FEMA’s Alternative Cost-Effectiveness Method announced on Oct. 6 is consistent with this recommendation and should be extended to other programs. The report emphasized that “criteria beyond the BCA and property values should be considered for historically marginalized communities in the methodology, including an emphasis on social and environmental benefits and prioritizing locations that have historically failed to compete for federal funding.” The NAC provided other recommendations to further a “programmatic approach towards equity”. These recommendations are associated with the FEMA 20222-2026 Strategic Plan objectives 1.2–Remove Barriers to FEMA Programs Though a People First Approach and 1.3–Achieve Equitable Outcomes for Those We Serve.