I think it is futile to argue whether the decision to put FEMA in the department was an intellectual mistake. What I don’t think is futile, however, is to think through the implications of yet another major reorganization.
Let’s remember that the organization of a federal agency is more than the sum of a set of boxes and chains of command — it is a complex web of relationships, budgetary arrangements, congressional oversight, and public understanding of how an organization does business (and how the public does business with the organization).
An organization such as FEMA can work well in spite of a sub-optimal organizational chart — if the organization and its people have time to establish relationships with other entities, define lanes of responsibility, and communicate responsibilities and avenues of redress to the public. Along with a motivated and high-performing workforce, these are the real factors of success in a federal agency, not the way boxes are arranged on a chart. Shifting offices, reporting chains, and personnel disrupts these critical elements to organizational success, and an organization can take years to reestablish an understanding of responsibilities, relationships, and authorities.
A significant reorganization like the one proposed by Kamarck would effectively wipe those gains clean, and force FEMA back two to four years in terms of defining lanes of responsibility and building the relationships that make an organization work. It is an rearrangement that might look good on the white board of a classroom or a Power Point slide, but it is a rearrangement the nation can’t afford.