American Institute of Architects Issues Public Comment on FEMA Notice

WASHINGTON, May 12 -- Sarah Dodge, senior vice-president of advocacy and relationships at the American Institute of Architects, has issued a public comment on the Federal Emergency Management Agency's notice entitled "Hazard Mitigation Assistance: Building Resilient Infrastructure and Communities". The comment was written and posted on May 11, 2020:

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The American Institute of Architects (AIA) welcomes the opportunity to submit comments to the Federal Emergency Management Administration (FEMA) on the proposed policy for the Building Resilient Infrastructure and Communities (BRIC) program.

As it has for over 160 years, AIA works to protect the public's health, safety and welfare. AIA's more than 95,000 members seek to advance our nation's quality of life through design. Communities rely on well-designed infrastructure that can be resilient in the face of severe weather events. This is even more important now as climate change will continue to increase the frequency and severity of major storms. The infrastructure we build today will be called upon to outperform itself in the years ahead. AIA applauds FEMA for their serious work while drafting the BRIC program's proposed policy guidance to increase the resilience of U.S. infrastructure.

As FEMA staff consider comments to the BRIC program's proposed policy guidance, AIA urges FEMA to consider explicitly including improvements to "vertical infrastructure" as eligible uses of FEMA assistance under the Capacity and Capacity-Building Activities. This should include investment in civic buildings, affordable housing, and schools that are better able to withstand severe weather events. These buildings are vital to promote community resilience, both as potential hubs to shelter inhabitants during the storm, but also as conduits for community life to continue more quickly once the danger has passed. Over 80 percent of Americans agree that buildings are infrastructure according to an AIA poll commissioned in 2016./1

FEMA should include efforts to address disease outbreaks among eligible mitigation projects. The ongoing COVID-19 pandemic has exposed vulnerabilities in our nation's building stock as Americans are called to shelter in place and hospital surge capacity is stretched beyond its limit. This crisis has accelerated the need to reimagine public spaces and infrastructure to be prepared for bio-threats. BRIC policy should encourage this type of mitigation.

AIA commends FEMA for including the adoption and enforcement of hazard resistant building codes as one of the proposed policy's five underlying principles and welcomes the additional flexibility provided on an annual basis through Notice of Funding Opportunities (NOFOs). AIA recommends the adoption and enforcement of hazard-resistant building codes as the preeminent driver of BRIC program implementation, as code adoption is one of the most effective methods to build resilience into the building stock./2

Additionally, to build upon the gains of effective code adoption, AIA recommends the BRIC program provide non-financial technical assistance when requested from communities in need. Doing so protects communities by promoting to adherence to up-to-date building codes, while also saving money for U.S. taxpayers.

In fact, the latest findings from a 2018 report compiled by the National Institute of Building Sciences (NIBS) and sponsored by FEMA, among others, found that the potential benefit-cost ratio (BCR) of buildings designed to meet the 2018 International Building Code (IBC) to be a 11:1/3 return on investment.

AIA thanks FEMA for its consideration of these comments and for the agency's important work to make American infrastructure more resilient for the communities it serves. We look forward to continued work with FEMA on this critical effort.

Sincerely,

Sarah

Sarah Dodge

Senior Vice-President of Advocacy + Relationships

The American Institute of Architects

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Footnotes:

1/ https://cdn.ymaws.com/www.nibs.org/resource/resmgr/mmc/NIBS_MSv2-2018_Interim-Repor.pdf

2/ https://cdn.ymaws.com/www.nibs.org/resource/resmgr/mmc/NIBS_MSv2-2018_Interim-Repor.pdf

3/ https://cdn.ymaws.com/www.nibs.org/resource/resmgr/mmc/NIBS_MSv2-2018_Interim-Repor.pdf

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The notice can be viewed at: https://www.regulations.gov/document?D=FEMA-2019-0018-0001

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