A confidential memo drafted earlier this year reveals that the Trump administration, led by Homeland Security Secretary Kristi Noem, is actively pursuing a plan to dismantle the Federal Emergency Management Agency (FEMA) and replace it with a smaller, rebranded disaster response organization.

The internal document, dated March 25 and reviewed by Bloomberg News, was written by then-acting FEMA Administrator Cameron Hamilton at Noem’s direction. It offers a blueprint for dramatically reducing the agency’s size and role, transferring some responsibilities to other federal departments, and scrapping others entirely. While President Trump and Noem have publicly stated their intent to overhaul FEMA, the memo provides a first look at specific proposals under consideration — some of which could take effect as early as late 2025.

Importantly, FEMA cannot be legally dissolved without an act of Congress. However, the document outlines several executive actions that could significantly scale back the agency’s authority and funding without new legislation.

A Blueprint for a Smaller FEMA

The seven-page memo suggests eliminating or sharply curtailing many of FEMA’s current programs. Among the most sweeping changes proposed are ending long-term housing assistance for disaster victims, stopping enrollments in the National Flood Insurance Program (NFIP), and scaling back federal financial support for all but the most catastrophic events.

“This would mean FEMA would only respond to disasters on the scale of 9/11, Hurricane Katrina, or Superstorm Sandy,” said Carrie Speranza, a former FEMA advisor and now president of the U.S. Council of the International Association of Emergency Managers.

When asked for comment, DHS, FEMA, and the White House declined to address the memo directly. Instead, DHS spokesperson Tricia McLaughlin stated, “FEMA, as it currently operates, is coming to an end. Under Secretary Noem and Acting Administrator Richardson, we’re shifting from an inefficient, centralized system to a lean, responsive force that puts state governments in the lead.”

Hamilton, who resigned in May, did not comment on the memo.

FEMA’s Track Record and the Push for Reform

Founded by President Jimmy Carter in 1979, FEMA has long been criticized from both sides of the aisle — whether for slow responses to major hurricanes like Katrina and Maria or for its mounting costs amid climate change and increased storm frequency.

A number of congressional proposals have surfaced in response. One, sponsored by Republican Rep. Clay Higgins of Louisiana, would scrap FEMA entirely and instead distribute disaster relief funding through block grants to states — mirroring other social programs. Bipartisan alternatives call for reforming FEMA’s grant and reimbursement systems while keeping the agency intact.

The memo prepared by Hamilton takes a more aggressive approach. It emphasizes cutting federal disaster costs by ending long-standing programs, limiting financial assistance, and placing the burden of disaster response more squarely on state and local governments.

Many of the recommendations align with the Heritage Foundation’s Project 2025 framework, which also targets government downsizing. However, even Project 2025 stops short of suggesting FEMA’s elimination.

What the New FEMA Might Look Like

According to the memo, Noem tasked FEMA with outlining a plan for a “smaller footprint” centered around only the most essential disaster functions.

Hamilton’s proposal envisions a streamlined agency that would still coordinate immediate disaster response — such as managing rescue teams, logistics, and emergency supplies — but would exit long-term recovery efforts almost entirely.

That means federal housing aid for disaster survivors would be eliminated, including rental support, direct housing, and FEMA trailers. “States just don’t have the infrastructure to handle these needs alone,” said Michael Coen, FEMA’s former chief of staff under President Biden. “This would leave many communities behind.”

The document concedes that most states currently lack the capacity to take on these responsibilities. It proposes an initial phase in which the federal government provides training and grants to build up state systems, followed by a withdrawal of that support over time.

Flood Insurance, State Burdens, and Rebranding

Hamilton’s memo also criticizes the National Flood Insurance Program, which insures over 4 million homes, as unsustainable. The NFIP has long operated at a deficit, and climate change has exacerbated the problem. Hamilton suggested that Trump could potentially halt new policy sales or renewals via executive action, though more legal research was needed.

To reflect the reimagined agency, Hamilton floated four possible new names:

• Office of Crisis Management (OCM)

• Office of Crisis Response (OCR)

• National Crisis Response Agency (NCRA)

• National Office of Emergency Management (NOEM) — a possible nod to Secretary Noem herself

Legislative vs. Executive Power

Although sweeping changes like eliminating the NFIP or major housing aid programs would require congressional approval, the memo lists actions the executive branch could take immediately. One such move already took place: in April, FEMA discontinued a grant program that supported community resilience projects — an initiative flagged for elimination in the memo.

Hamilton also advised bypassing the FEMA Review Council, a Trump-established body meant to propose reforms by November. Instead, he urged immediate action to implement key cuts.

Despite this, the Review Council met for the first time in May and continues its work. DHS’s McLaughlin confirmed the council is developing a detailed transformation plan to be released later this year.

Both Noem and Trump reaffirmed last week that they intend to dissolve the agency after the 2025 hurricane season.

Looking Ahead

Disaster experts caution that reducing FEMA’s role could have serious consequences, particularly for states that lack the resources or infrastructure to handle major emergencies.

“If a devastating hurricane or earthquake strikes in the coming months, we may see this conversation shift dramatically,” said Coen. “Disasters don’t wait for policy experiments.”