5 Community Organizations, Individuals Issue Joint Public Comment on FEMA Notice

WASHINGTON, July 28 -- Five community organizations and individuals, have issued a joint public comment on the Federal Emergency Management Agency notice entitled "Request for Information on FEMA Programs, Regulations, and Policies". The comment was written on July 20, 2021, and posted on July 21, 2021:

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These comments are submitted on behalf of the following community organizations and individuals:

* Community Organization: Deborah Sims, East End NRZ Market & Cafe

* Individuals:

- Suzi Ruhl, JD, MPH; Hilary Hahn, EdM, MPH; Caroline Simmons, MA: for purposes of identification only, affiliated with the Elevate Policy Lab, Yale School of Public Health and Yale Child Study Center, Yale School of Medicine

- Jean Adnopoz, MPH; Joseph Woolston, MD: for purposes of identification only, affiliated with Yale Child Study Center, Intensive In-home Child & Adolescent Psychiatric Services

- Kieran O'Donnell, PhD; Maggie Holland, PhD, MPH: for purposes of identification only, affiliated with the Yale Child Study Center

- Sarah Lowe, PhD: for purposes of identification only, affiliated with the Yale School of Public Health

- James Comer, MD, MPH; Fay Brown, PhD; Camille Cooper, EdD: for purposes of identification only, affiliated with the Yale Child Study Center, Comer School Development Program

- Karen Frankel, PhD, Ashley Sward, PsyD, Kelly Glaze, PsyD & Susanne Klawetter, PhD for purposes of identification only, affiliated with Warm Connections, University of Colorado, School of Medicine

The lead community organization informing this testimony is the East End NRZ Market & Cafe (NRZ Market), which works with the East End NRZ in Bridgeport, CT. The NRZ Market was incorporated in 2019 in response to the community-defined need of food insecurity. Since its inception, the NRZ Market & Cafe provides residents with access to healthy foods, job opportunities, a local gathering place to build neighborhood cohesion., and the opportunity to purchase fresh, local produce that will combat the issue of unhealthy lifestyles that afflicts this low-income community. Their mission is to create a space where our neighborhoods can invest in themselves, have access to healthy affordable foods and through collaboration eliminate the systemic racism and family violence that exist in urban communities. The NRZ Market is the 2019 National Winner of Aetna's Healthiest Cities Challenge in partnership with American Public Health Association and National Association of Counties. It is now championing Triple Bottom Line Justice and the provision of maternal mental health care to underserved mothers bearing the burden of pollution, disease, poverty and violence. Individuals collaborating in response to this RFI are experts in environmental justice and law; food insecurity; community revitalization; child, maternal, family and caregiver mental health, including traumatic events; and early childhood education.

Contact for questions or other follow-up on your response: Suzi Ruhl, [email protected]

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Comments on FEMA Programs, Regulations, and Policies

Introduction

Through Executive Orders 13985, 13990, and 14008, the Biden-Harris Administration is providing an unprecedented opportunity to achieve Triple Bottom Line (environmental, health and economic) Justice for overburdened, underserved and historically disenfranchised populations facing disproportionately high and adverse climate-related impacts. This opportunity extends to both authority and appropriations that can bolster resiliency to climate change. FEMA plays a crucial role in identifying and eliminating systemic barriers to benefits and opportunities for people of color and other underserved groups. FEMA's role extends from its direct function in responding to natural and manmade disasters and its leadership role in managing whole of government solutions to climate-related impacts and resilience for underserved and disadvantaged communities. To ensure that is programs, regulations and policies advance climate equity for all conformance with Executive Orders 13985, 13990, and 14008, FEMA must incorporate full consideration of the mental and interrelated physical health and well-being of children, from the prenatal period through the life course, and those who care for them--parents and other caregivers--(hereinafter "caregivers"). This consideration should apply a three-generation approach that includes children, parents and grandparents, and future generations (hereinafter "3Gen"), with a special focus on populations of color and low-income families who experience disproportionately high and adverse human health, environmental and economic risks.

Critical Need for Revised Approach and Action: The persistent neglect of children and caregivers' mental health has been compounded by the climate crisis as well as the COVID-19 pandemic. The loss of human lives and devastating financial impacts from these global threats - which disproportionately fall on low-income populations, people of color, and indigenous peoples - have augmented pre-existing mental health risks, both directly and by increasing the likelihood of child maltreatment and family violence. Significant evidence supports urgent, vital action. In FY 2018, an estimated 678,000 children were victims of abuse or neglect nationwide, a rate of 9.2 victims per 1,000 children in the population./i

The lifetime economic costs for child maltreatment can total more than $830,000 for every child affected./ii

In 2019, it was estimated that 7.7 million American children (16.5%) had at least one mental health disorder./iii

Due to the stress, disruptions, and isolation of the COVID-19 pandemic, this number is rising, especially among Black and Hispanic children./iv

One in five pregnant women struggle with their mental health, costing the US economy $14.2 billion per year,/v while untreated maternal perinatal anxiety/depression doubles a child's risk for a probable mental disorder, with effects observed as early as 4 years of age./vi

Cost-effective evidence-based interventions that support pregnant people and caregivers can prevent perinatal depression,/vii reduce child maltreatment/viii and improve a myriad of child health outcomes but access, especially for families of color, remains a fundamental challenge./ix

FEMA and Whole of Government Solutions: To equitably serve individuals and communities currently and historically underserved, the federal government response to climate change must activate comprehensive, whole-of-government solutions through interagency collaboration and individual federal agency policies and actions (e.g., programs, services, processes, and operations). Methods and leading practices must be sustained by overarching commitments expressed as federal agency missions. More specifically, the following whole of government policy should be adopted and implemented for climate related duties:

* Each federal agency shall make as part of its mission achieving mental and interrelated physical health and well-being, including the elimination of health disparities, for children and caregivers. Further, each federal agency shall identify and address in its programs, policies and activities, as appropriate, the provision of basic needs and safety of historically disenfranchised and structurally marginalized, overburdened and underserved people of color, low-income populations, and indigenous people.

In addition, in order to bolster resilience and address climate-related disproportionately high impacts of climate change, the federal government must be guided by principles that are accountable to the conditions of these communities and that will act as a foundation for interagency coordination and federal agency action to recognize the fundamental right of every child in the US to a safe, healthy, and nurturing environment from the prenatal period through the life course. All federal agencies have a responsibility to address this duty, in whole or in part, through federal policies and investment coordination and leveraging of federal government financial, staff, programmatic and other resources. The following principles should serve as coordinates for whole of government methods and practices:

* Mental health and interrelated physical health are foundational to the well-being of individuals and a successful society.

* Precedence must be given to people of color, low-income populations and indigenous peoples who are overburdened, underserved, and historically disenfranchised.

* Priority must be focused on caregivers and children, recognizing and promoting the conditions that facilitate attachment and nurturing care carried out in a culturally respectful and sensitive manner from the prenatal period through the life course.

* The framework for federal agency response must account for the intersection between people (i.e., health and economics) and place (i.e., environment and climate) and considers adversity, basic needs and safety, stigma and intersectional risk while providing stability and safety for those most likely to experience disruption. It must provide stability and safety for those most likely to experience disruption. People and place considerations include social determinants of health (e.g. housing, food security, transportation, poverty, racism and discrimination, equitable access to care) and natural and human-made disasters. Communities and neighborhood resiliency must be prioritized, especially within minority, low-income and tribal indigenous populations who are most negatively affected by social determinants of health and natural or human-made disasters.

* Provide a transparent and inclusive process to ensure equitable engagement by experts from academia, those with lived experience, nonprofit & philanthropic organizations and the private sector and across the domains of health, environment & climate, and economy to inform government decision-making and action

Illustration of Underserved Communities: While these comments apply to underserved communities throughout the country, it is informative to recognize the conditions through an illustrative community. Bridgeport, CT serves to clarify the complex relationship between inequity, social determinants of health (SDoH), children and caregiver mental health, environmental sustainability and economic vitality, under the umbrella of climate change. As a city located at the juncture of the Pequonnock River and Long Island Sound and divided by creeks, rivers, and low-lying wetland areas, Bridgeport experiences extreme flooding and stormwater challenges./x

The East End is bearing many burdens that impact ways in which community members live, learn, work, play, develop and worship; these burdens affect a wide range of health, functioning, and quality-of-life outcomes and risks. Regarding demographics,/xi the city of Bridgeport is the most densely populated, ethnically diverse, and socially vulnerable city in Connecticut. The East End neighborhood (census tracks 743 and 744) is 1.2 square miles and has a population of approximately 8000. Bridgeport's East End has a diverse population that is 49% Black (4,560 people), 42% Latino (3,877 people), 5% white (506 people), and 4% Other Race (366 people). Regarding economic conditions, Bridgeport's East End ranks the lowest in Fairfield County along many measures of community well-being, including unemployment (17%), poverty (26%), life expectancy (76 years), severe housing cost burden (33%) and median household income ($36K). Altogether, these census tracts have some of the highest social vulnerability indices in the country: 0.948 and 0.951, respectively. This contrasts with neighboring census tract 805, which has a social vulnerability index of 0.098./xii

Regarding health inequities and social determinants of health, burdens faced by East End residents emanate from lack of access to quality health care, nutritious food, affordable housing, and barriers to transportation. Food insecurity/xiii is a pressing concern for as many as two-thirds of East End residents./vi

26.37% of Bridgeport residents are facing food insecurity and receiving SNAP benefits compared to 11.89% of Connecticut's residents overall./xxvii

According to a Bridgeport Community Health Needs Assessment, food cost can be a major hindrance to healthy eating/vii contributing ultimately to chronic disease burden. In the East End, 33% of the population lives no more than 0.5 miles from the nearest supermarket; however, there is lack of transportation infrastructure/viii and 29% of households do not own an automobile./ix

The diabetes mortality rate among Blacks is three times higher and the rate of obesity is higher, as 37% of non-Hispanic Blacks were considered obese compared to 24% of non-Hispanic white respondents. 16.14% of Bridgeport residents are uninsured,/xxviii and over 43% of Bridgeport's East End residents are rent-burdened, allocating more than 30% of their household income to rent; 25% of households are extremely rent-burdened, allocating over 50% of income to rent. Black Bridgeport residents are more than three times less likely to have access to a vehicle than residents overall in Bridgeport, leading to barriers in accessing jobs and health care.

Regarding maternal adversity, women disproportionately shoulder the stressors of food insecurity and pollution, and the resulting morbidity, for themselves and their families. In Bridgeport, 48.5% of families are single-parent families, the largest share in Fairfield County and nearly double the state average of 26%./xx

COVID-19 has exacerbated previously existing inequities for women and particularly women of color in Connecticut. 1 in 3 families have not been able to find quality childcare during the pandemic, housing insecurity has risen, food insecurity is expected to increase by 28%, more women report mental health concerns than men, women have filed for more unemployment claims and four times more women are leaving the workforce than men./xxi

Additionally, it has been well-established that these economic stressors can adversely impact women's mental health. In turn, maternal depression can lead to reduced earnings, lower wages and loss of employment, as well as to negative outcomes for children and families, including poorer mental health/xiv and lower academic achievement./xv

Additionally, this can contribute to the multi-generational cycle of poverty. Proposed efforts will simultaneously directly address MMH and engage community members in actively and directly addressing SDoH that negatively impact physical and mental health.

Regarding climate change, pollution and the neighborhood and built environment,/xvi environmental conditions such as air pollution, groundwater contamination, and housing proximity to contaminated sites also pose serious challenges to health and well-being in the East End. While the neighborhood has a vibrant history that included numerous factories, shops, restaurants, churches and residences, today industry has largely withdrawn, leaving polluted tracts that qualify as brownfield sites and many abandoned buildings./v

Bridgeport's location along the coast of the Long Island Sound creates vulnerability to climate and environmental disaster. The East End is emblematic of Black, Indigenous and People of Color (BIPOC) communities across the county who are more likely to live in geographical locations in close proximity to industries with a high carbon footprint including emissions from chemical plants, paper mills, transportation depots, and areas with high traffic concentration. According to the data, BIPOC communities concomitantly experience a particularly high incidence of asthma and related acute and chronic long-term physical and behavioral health outcomes (e.g. non-Hispanic Blacks were 40% more likely to have asthma than non-Hispanic white people; non-Hispanic Blacks were nearly three times more likely to die from asthma related causes than non-Hispanic white people)./xii

In Connecticut, asthma rates are higher among Black people within Connecticut's urban centers, including Bridgeport. According to the CT Department of Public Health, Black children are twice as likely to have asthma as white children.

Conclusion: Ultimately, the negative effects of air pollution and related climate change have a disproportionate impact on women of color, which contributes to adverse maternal health and mental health outcomes./xvii

Research examining 32 million births in the U.S. shows that women exposed to poor air pollution have higher rates of preterm birth and stillbirth and the risk of stillbirth was twice as high for black mothers as for white mothers;/xiv these are key risk factors for postpartum depression./xv

Poor air quality has also been associated with poor maternal health outcomes such as low birthweight, gestational diabetes mellitus, gestational hypertension and preeclampsia./xvi

Climate risk factors, such as extreme heat, air pollution, flooding, and hurricanes have also been shown to directly impact maternal health, as well have a negative impact on mental health./xviii

Black women face these exposure risks and health consequences at greater rates.xix Combined, these factors contribute to the maternal morbidity and mortality crisis in the U.S., in which black mothers are three times as likely to die from childbirth as white mothers and 38% of women of color have postpartum depression compared to 13-19% for all postpartum women.

Communities with fewer social, economic, and political resources experience higher levels of exposure to environmental stressors in both terms of frequency and magnitude and are less able to deal with these hazards as a result of limited knowledge of exposures and disenfranchisement from the political process./xxii

Too often, individuals are not in control of the factors that make them sick and respond unconsciously to environmental cues. Therefore, moderating unhealthy behaviors requires creating more supportive environments for healthy choices./xxiii

In addition, while there has been increasing focus on supportive environments for physical activity and nutrition, the family environment in childhood is particularly important and can have far-reaching consequences on physical and mental health, as well as mortality./xxiv

Issue One re Environmental Justice

FEMA Questions:

General 3): Are there FEMA programs, regulations, and/or policies that do not promote environmental justice? How can those programs, regulations, and/or policies be modified, expanded, streamlined, or repealed to promote environmental justice?

Specific (2): Public Assistance: Are there measures FEMA could take to more effectively bolster or incentivize resilience to the impacts of climate change?

Commenting Experts:

* Suzi Ruhl, JD, MPH; Hilary Hahn, EdM, MPH; Caroline Simmons, MA: for purposes of identification only, affiliated with the Elevate Policy Lab, Yale School of Public Health and Yale Child Study Center, Yale School of Medicine

* Sarah Lowe, PhD: for purposes of identification only, affiliated with the Yale School of Public Health

* James Comer, MD, MPH; Fay Brown, PhD; Camille Cooper, EdD: for purposes of identification only, affiliated with the Yale Child Study Center, Comer School Development Program

Issue Topic: Recognition of subpopulations at disproportionately high and adverse risk from climate change/natural disasters and supporting their meaningful engagement is essential for promoting environmental justice in FEMA programs, regulations and policies.

Problem Summary: Federal government agencies, including FEMA, are charged with "identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations."/xviii

(See EO 12898). Fundamental to this duty is recognition of those who bear the burdens of pollution, disease, poverty and crime. FEMA's programs, regulations and/or policies, including the National Disaster Recovery Framework, do not sufficiently acknowledge these "special populations" whose conditions make them more vulnerable to the impacts of natural disasters. Furthermore, without this refined recognition of vulnerable conditions, FEMA is limited in its ability to support their meaningful engagement in decision-making and programing.

Solution: FEMA should adopt a consistent definition of subpopulations at highest risk from climate change that can be applied across the federal government through whole-of-government solutions. In addition, FEMA should revise its policies and programing to strengthen meaningful engagement of vulnerable subpopulations.

More specifically, as a foundational measure, FEMA should adopt an inclusive definition of highest risk subpopulations so that unique characteristics and conditions are addressed, and a general population approach is avoided. This definition should be incorporated into the National Disaster Recovery Framework and acknowledge those populations described in EO 14008. Accordingly, the following definition should be adopted:

Vulnerable populations are "groups of people especially at risk to impacts of climate change due to their location and/or because they are disadvantaged, historically marginalized, overburdened, and underserved. These populations are defined by characteristics, including children (prenatal through adolescent), pregnant women, elderly individuals, communities of color, households and people with limited English proficiency, immigrants, individuals with chronic physical and mental conditions, and individuals with disabilities. These populations are defined by conditions, including those who experience disproportionately high and adverse human health, environmental, climate-related and other cumulative impacts; low-income communities and those who lack resources or have less access to services; and, people who are homeless or at risk of homelessness. Additional groups to be recognized are specific groups who are at high risk of distress or adverse mental health outcomes following exposure to climate-related disasters, including infants and children, the elderly, pregnant and postpartum women, first-responders, those with pre-existing mental illnesses, those with low socio-economic status, and the homeless.

Subsequently, FEMA should revise its public engagement programing for subpopulations whose members may have additional needs before, during, and after a natural disaster. Functional areas should include but not be limited to maintaining independence, communication, transportation, supervision, medical care, mental health care, basic needs, and safety.

Model Programming as Illustration

Federal statutory authority supports the need for enhanced action to address populations whose characteristics and conditions put them at heightened risk from natural disasters. For example, Section 416 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. Sec. 5183 authorizes FEMA to fund mental health assistance and training activities in areas that have been declared a major disaster by the President. Further, important work is underway to recognize and reach the most underserved, overburdened and historically disenfranchised communities at highest risk to climate disasters. For example, the Crisis Counseling Assistance and Training Program (CCP) is a federally funded supplemental program administrated by the U.S. Department of Homeland Security (DHS) Federal Emergency Management Agency (FEMA). This authority and this FEMA program provide the foundation to expand services to promote environmental justice. The following examples serve as model approaches that can inform the expansion of FEMA programs in order to address the characteristics and conditions of those at heightened risk from natural disasters and foster community engagement responsive to the needs and culture of underserved populations.

The MOMS Partnership and Civic Justice Engagement Project (MOMS Project, Yale Elevate Policy Lab): The Yale Elevate Policy Lab based at the Yale School of Public Health was launched in 2019 to leverage established success using data-driven methods to treat depression through community-based interventions. Elevate's mission is to elevate the understanding of improved mental health as a public sector strategy to disrupt poverty. Elevate's vision is that as historically disenfranchised and marginalized communities experience strengthened mental health, their capacity to participate in the workforce increases, the outcomes for children improve, and the cycle of poverty is disrupted for women and their families. Elevate is a practice-to-policy lab, working closely with government and community partners across the country to implement the nationally recognized MOMS Partnership model, rigorously evaluate the outcomes and inform policy solutions.

Elevate is launching its MOMS Project in collaboration with the NRZ Market, which is discussed fully in Area 1)./xix

The MOMS Project is a community-led initiative to equitably build individual and community resiliency by tackling highest priority conditions created by health, economic, environmental and climate challenges. The programming aims to strengthen individual mental health and social support and build capacity of individuals and communities to confront and resolve barriers to well-being through civic justice engagement. The proof of concept was launched in the East End Neighborhood of Bridgeport, CT, and is simultaneously addressing people and place by integrating mental health care with Brownfields to Healthfields (B2H), a community driven, multi-stakeholder approach to transform contaminated properties into community spaces that meet essential needs. B2H-Natural Disasters will be used to address climate related crises, including flooding which exacerbates exposure to land and water pollution. Providing outreach, screening and engagement at other community hubs including the NRZ Market, the MOMS Project seeks to address the social determinants of health (SDoH) that contribute to maternal depression, as well as the impact of maternal depression on children and families. The following steps are applied: (1) proven outreach, engagement and individual and community capacity-building strategies; (2) an innovative approach to the meaningful engagement of mothers and adolescent girls in government decisions affecting their health and wellbeing; and (3) a proven intervention to address maternal depression as pathway to social and economic mobility. Ultimately, Elevate's model can help disaster survivors understand their current situation and reactions; reduce stress and providing emotional support, promote the use or development of coping strategies, and connect survivors with other people and agencies who can help them in their recovery process. Accordingly, FEMA could more effectively support mental health assistance and training activities in presidentially declared major disaster areas by institutionalizing programs, such as Elevate's MOMS Partnership and Civic Justice Engagement model, that would strengthen FEMA's Crisis Counseling Assistance and Training Program (CCP). This institutionalization can include certification of programming as well as funding support for broad scale implementation.

Parents, Partners and Peers program (PPP, Yale Child Study Center Comer School Development Program): The Comer School Development Program (SDP) within the Yale Child Study Center is widely recognized as a successful approach to educational change, providing a systems-change framework for school organization and management that is designed to support students' holistic development and learning. The SDP promotes the importance of involving parents in educational decision making and practices, having a long history of helping parents help change schools so that they support development that enhances the academic and social learning of their children. The SDP's Parents Partners and Peers (PPP) program is a model for stakeholder and community engagement that is integrated with core challenges faced by communities regarding education. Recognizing that the positive support for optimal development at home and effective advocacy of their children at school requires learning and support opportunities for parents, the PPP program builds upon the importance of positive home-school relationships and developmentally supportive child rearing and education. Notably the PPP Program is a hybrid with the peer-led Smart and Secure Children's program developed at Morehouse School of Medicine. In practice, the PPP program is a peer-led, conversational approach to increasing parent knowledge of child development principles and practices to enhance their child-rearing repertoire. Further, it provides a practical application of that developmental approach within a cultural context. The program utilizes a community-based approach and involves parents at three levels: Parent Mentors, Parent Leaders, and Parent Peer Learners. Ultimately, the overarching goals are aligned with avenues to promote community engagement: to help parents gain a deeper understanding of child development principles; and increase their capacity to apply those principles to their day-to-day child rearing practices; and, to work with parents to develop a network of peers and develop skills that can be utilized with other adults, agencies, and institutions; develop skills that can prepare them to illicit positive interactions with outside systems that allow them to feel a sense of inclusion rather than exclusion, and capacity that promotes their sense of confidence and competence to participate in civic engagements.

Accordingly, FEMA could apply the PPP program to strengthen FEMA's programming to more effectively bolster and incentivize resilience to the impacts of climate change. For example, principles and measures of the PPP program can be applied to FEMA efforts regarding Multihazard Emergency Planning for Schools./xx

In addition, the PPP program elements can inform FEMA's Public Assistance Division as it engages with the U.S. Department of Education's Office of Safe and Healthy Students (OSHS), Readiness and Emergency Management for Schools (REMS) Technical Assistance (TA) Center on activities supported by the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) for evidence-based, full-service community schools and related approaches.

Rationale: There is consistent agreement across federal government that measures to identify, and address climate change effects must recognize populations who are at disproportionately high and adverse risk from climate change/natural disasters. (see Executive Orders 13985, 13990, and 14008). Further, it is recognized that Environmental and technological disasters hit some people disproportionately hard, among them the poor, marginalized racial or ethnic groups, single parents, minority-language speakers, recent migrants, children, the elderly, and persons with disabilities (Morrow and Enarson 1999)./xxi

Given this recognition, it is important to establish an inclusive definition of "highest risk populations" so that unique conditions (e.g. physical and mental health, life stage, access to services and amenities, high energy burden) can be addressed, and a general population approach can be avoided. This approach is consistent with federal and state government approaches to identify communities with environmental justice concerns.

It is noted that Executive Order On Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, EO 13985xxii defines "equity" and "underserved communities." Subpopulations recognized include Black, Latino, and Indigenous and Native American persons, Asian Americans and Pacific Islanders and other persons of color; members of religious minorities; lesbian, gay, bisexual, transgender, and queer (LGBTQ+) persons; persons with disabilities; persons who live in rural areas; and persons otherwise adversely affected by persistent poverty or inequality. This list is further defined as "populations sharing a particular characteristic, as well as geographic communities, that have been systematically denied a full opportunity to participate in aspects of economic, social, and civic life." While EO 13985 provides additional clarity, with respect to climate change, it is insufficient. Definitions applied by multiple government bodies are included and support the recommended definition of "vulnerable populations" for incorporation by FEMA, including the following:

* White House Hurricane Sandy Rebuilding Strategy recognizes vulnerable populations as "groups of people especially at risk to impacts of a major storm due to their location or because they are overburdened and lack resources or have less access to services." The strategy explained "Vulnerable Populations" by providing the following text: "The Task Force understands that the affected areas include a diversity of businesses, neighborhoods, residents, and workers that may have been disproportionately vulnerable to the impacts of Hurricane Sandy due to their location, limited financial or other resources, less access to emergency services and support, or other disadvantages. Accordingly, the Task Force's Rebuilding Strategy seeks to address the needs of such 'vulnerable populations,' which is meant to include: low-income communities, overburdened populations, children and youth, elderly individuals, certain communities of color, households and people with limited English proficiency, immigrants, individuals with chronic medical conditions, people who are homeless or at risk of homelessness, and individuals with disabilities." Accordingly, the White House Hurricane Sandy Rebuilding Strategy recognized the importance of delineating individuals and communities at heightened risk from natural disasters, rather adopting a generalized approach that only acknowledged individuals affected by natural disasters.

* The US Global Climate Change Research Program also addressed the physical states or conditions that increase vulnerability. It emphasized that older adults, young children, pregnant women, and people with chronic health conditions or mental illness are more susceptible to harm from effects of climate change. US Global Climate Change Research Program See: 16. USGCRP, 2016: The Impacts of Climate Change on Human Health in the United States: A Scientific Assessment. Crimmins, A., J. Balbus, J.L. Gamble, C.B. Beard, J.E. Bell, D. Dodgen, R.J. Eisen, N. Fann, M.D. Hawkins, S.C. Herring, L. Jantarasami, D.M. Mills, S. Saha, M.C. Sarofim, J. Trtanj, and L. Ziska, Eds. U.S. Global Change Research Program, Washington, DC, 312 pp./xxiii

Accordingly, the US Global Climate Change Research Program acknowledged the heightened risk presented by physical states or condition, relating to age and physical and mental health status. FEMA should adopt an overall policy that provides this recognition.

The State of California Governor's Office of Planning and Research pursuant to Executive Order B-30-15 identified factors that contribute to vulnerability of people and communities to the impacts of climate change: Existing inequities, institutionalized racism, or exclusion; Poor environmental conditions, access to services, or living conditions; Physical states or conditions that increase vulnerability; Lack of investment and opportunities./xxiv

Accordingly, the State of California recognizes the vulnerabilities imposed by racial and other inequities, environmental conditions, and economic challenges. FEMA should adopt an overall policy that provides this recognition.

Regarding meaningful engagement and its relationship to vulnerable subpopulations, clarity is provided by the US EPA's environmental justice programming. The EPA's definition of "environmental justice" recognizes meaningful engagement as a fundamental principle. The two central pillars of environmental justice are fair treatment and meaningful engagement. Meaningfully engaging potentially impacted groups means: communities are given the opportunity to participate in decisions about activities that may affect their environment and/or health; public concerns have the capacity to influence the agency decision and will actually be considered during the decision-making process; and decision makers actively seek out and facilitate involvement of impacted groups. Further, EPA's delineation of "disproportionate impact factors" recognizes "participating in decision-making" as a factor. Meaningful engagement is also bi-directional: 1) adaptive and innovative approaches to public outreach (disseminating relevant information to the community), and 2) adaptive and innovative approaches to public participation (receiving the information and views of the community)./xxv

Accordingly, in order to engage minority and low-income populations who face added barriers to access and involvement, agencies should consider incorporating adaptive and innovative approaches to both public outreach and participation. Through meaningful engagement, agencies and efforts for minority populations and low-income populations may serve as an effective avenue for the agencies' ability to collect data used to inform the decision-making process./xxvi

Some progress has been achieved through public involvement advances made during the COVID-19 pandemic. For example, FHWA's Virtual Public Involvement program supports agencies' efforts to engage the public more effectively by supplementing face-to-face information sharing with technology./xxvii

Yet, there remains a component of the population--those bearing the burden of pollution, disease, poverty and crime--who remain disengaged and disenfranchised. Efforts to engage this subpopulation require deeper consideration of the barriers to their participation, which includes the conditions which preclude their civic engagement. To overcome these barriers, government should account for social determinants of health factors that limit engagement. SDoH lead to health inequities through social stratification and reduced political and social influence, which ultimately results in an imbalance of power between groups based on socioeconomic situation, race, ethnicity, and other characteristics. Approaches that seek to address SDoH but fail to consider the meaningful engagement of individuals and communities to confront the source of the inequities may be well-meaning but are ultimately insufficient. Government should also leverage key educational programming that provides a framework for engagement in government decision-making.

Ultimately, FEMA recognition of populations at highest risk from climate change can produce equitable, effective, and efficient programing that is accountable to human health and environmental outcomes for vulnerable subpopulations and that can foster meaningful engagement to promote environmental justice.

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Conclusion:

In addition to extensive property and infrastructure damage, climate change and subsequent natural disasters elevate risk to personal and population health disproportionately among underserved communities. While it is essential to implement clean and renewable energy as envisioned by Executive Orders 13985, 13990, and 14008, it is equally essential to protect the physical and mental health of communities as part of climate change solutions. This requires whole of government solutions that account for the disproportionate adverse physical and mental health impacts associated with climate/air pollution on people of color and other underserved groups (especially to pregnant women of color) and beneficial physical and mental health impacts of climate measures (e.g. energy efficiency and weatherization.) Accordingly, FEMA's policy, regulations and programing to address environmental justice, resilience and systemic barriers and individual and public needs must be expanded to account for human health and the intersection with infrastructure.

View full comment at: https://downloads.regulations.gov/FEMA-2021-0011-0242/attachment_1.pdf

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Footnotes:

i/ https://www.childwelfare.gov/pubPDFs/canstats.pdf

ii/ Peterson, C., Florence, C., & Klevens, J. (2018). The economic burden of child maltreatment in the United States, 2015. Child Abuse & Neglect, 86, 178-183.

iii/ Whitney, D. G., & Peterson, M. D. (2019). US national and state-level prevalence of mental health disorders and disparities of mental health care use in children. JAMA Pediatrics, 173(4), 389-391.

iv/ Simon, N. M., Saxe, G. N., & Marmar, C. R. (2020). Mental health disorders related to COVID-19-related deaths. JAMA, 324(15), 1493-1494.

v/ Luca, D. L., & Sevak, P. (2019). Examining the Consequences of Poor Neonatal Health on the Family (No. 979c287754a74eeebb3ddaf3362184c9). Mathematica Policy Research.

vi/ O'Donnell, K. J., Glover, V., Barker, E. D., & O'Connor, T. G. (2014). The persisting effect of maternal mood in pregnancy on childhood psychopathology. Development and Psychopathology, 26(2), 393-403.

vii/ O'Connor E, Senger CA, Henninger ML, Coppola E, Gaynes BN. Interventions to Prevent Perinatal Depression: Evidence Report and Systematic Review for the US Preventive Services Task Force. JAMA. 2019 Feb 12;321(6):588-601. doi: 10.1001/jama.2018.20865. PMID: 30747970.

viii/ Donelan-McCall N, Eckenrode J, Olds DL. Home visiting for the prevention of child maltreatment: lessons learned during the past 20 years. Pediatr Clin North Am. 2009 Apr;56(2):389-403. doi: 10.1016/j.pcl.2009.01.002. PMID: 19358923.

ix/ Olds, D. L., Eckenrode, J., Henderson, C. R., Kitzman, H., Powers, J., Cole, R., ... & Luckey, D. (1997). Long-term effects of home visitation on maternal life course and child abuse and neglect: Fifteen-year follow-up of a randomized trial. JAMA, 278(8), 637-643.

x/ https://resilientbridgeport.com/bridgeport/

xi/ https://www.ctdatahaven.org/blog/report-socioeconomic-disparities-widening-fairfield-county https://censusreporter.org/profiles/14000US09001074300-census-tract-743-fairfield-ct/ https://ctdatahaven.org/data-resources/2016-bridgeport-neighborhood-profiles

xii/ https://svi.cdc.gov/map.html

xiii/ https://www.bridgeportct.gov/filestorage/341650/341652/341932/345868/BFPCFinalRecommendationsReport_2017.pdf https://www.bridgeportct.gov/filestorage/341650/341652/341932/345868/BFPCFinalRecommendationsReport_2017.pdf http://www.rebuildbydesign.org/our-work/all-proposals/winning-projects/ct-resilient-bridgeport East End Revitalization Zone Summary, 2005 https://www.aspeninstitute.org/wpcontent/uploads/files/content/docs/rcc/Barriers%20to%20Health%20Bridgeport%20Men%20053013.pdf

xiv/ O'Donnell KJ, Glover V, Barker ED, O'Connor TG. The persisting effect of maternal mood in pregnancy on childhood psychopathology. Dev Psychopathol. 2014 May;26(2):393-403. doi: 10.1017/S0954579414000029. Epub 2014 Mar 12. PMID: 24621564.

xv/ Pearson RM, Bornstein MH, Cordero M, Scerif G, Mahedy L, Evans J, Abioye A, Stein A. Maternal perinatal mental health and offspring academic achievement at age 16: the mediating role of childhood executive function. J Child Psychol Psychiatry. 2016 Apr;57(4):491-501. doi: 10.1111/jcpp.12483. Epub 2015 Nov 29. PMID: 26616637; PMCID: PMC4789117.

xvi/ https://www.scientificamerican.com/article/coal-fired-power-plants-virtually-extinct-new-england/

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