​These comments urge FEMA to delay implementing changes to the per capita and state minimum thresholds, given the ongoing pandemic and its associated economic challenges to state, local and tribal governments.  Once the pandemic is over and the economy has begun to recover, we urge FEMA to phase in the updated per capita and minimum thresholds, to give stakeholders the opportunity to plan for few federal declarations and therefore decreased availability of FEMA funds.  Finally, the comments urge FEMA to develop a clear, comprehensive, transparent, and reproducible methodology for how it will give the legislatively mandated greater consideration in its declaration recommendation process to severe local impacts and recent multiple disasters. ​