Community In-Power & Development Association Issues Public Comment on FEMA Notice

WASHINGTON, Nov. 20 -- Michelle Smith, marketing director at the Community In-Power and Development Association Inc., Port Arthur, Texas, has issued a public comment on the Federal Emergency Management Agency notice entitled "Request for Information on the National Flood Insurance Program's Floodplain Management Standards for Land Management and Use, and an Assessment of the Program's Impact on Threatened and Endangered Species and Their Habitats". The comment was posted on Nov. 16, 2021:

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My name is Michelle Smith, I am the Marketing Director for the Community In-Power and Development Association Inc. We are a non-profit community organization located in Port Arthur, TX. Port Arthur is home to around 54,000 people, has a poverty rate of 27% and is located on the Gulf of Mexico. Since 2005 we have seen an increase in severe hurricanes and tropical storms. However we were not prepared for what was to come during Hurricane Harvey in 2017. An estimated 80% of all homes on Port Arthur were severely damaged due to the flooding. The flood water came in during the night and surprised people in their beds. More than half of the properties flooded during Harvey were not in the 100-year flood plain. Neighborhoods like Montrose received around 8 feet of water. Many of our residents had to make a choice between thing such as paying for their medicine or purchasing flood insurance. Since then we have seen repeated flooding in our neighborhoods. With a median household income under $37,000, many of our residents cannot afford to repair their homes after flooding, much less elevate their home or purchase a home in a safer location, leaving them stuck in dangerous situations.

In response to questions posed in the FEMA RFI, we ask that you:

Question 1 - "cumulative substantial damage"

Please target FEMA financial support for buyouts and elevation for low-income residents whose homes flood repeatedly. Be flexible in the way that you determine whether or not residents have flooded repetitively. Use a realistic valuation method for "substantial damage" that makes people whole, and be transparent about how "substantial improvement and substantial damage" determinations are made.

Question 5 - "repeatedly flooded properties and managed retreat"

Increase NFIP funds to $100,000 for flood mitigation implementations, by using the Increased Cost of Compliance. Make buyouts feasible for homeowners by covering the cost of moving to desirable areas, far from flooding, pollution, or other hazards. Remove the cost-share requirement for low-income communities who are unable to meet those requirements.

Question 7 - "increase resilience to flooding"

Prohibit all construction within the 100-year floodplain and prohibit the use of fill in the 500-year floodplain.

Question 12 - "accounting for climate change"

Ensure that FEMA flood maps, modeling and calculations take climate change into account.

Take account of future development and land use change when creating and updating maps. Ensure that mapping is updated and it easily accessible to the public.

View image at https://downloads.regulations.gov/FEMA-2021-0024-0091/attachment_1.png

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The notice can be viewed at https://www.regulations.gov/document/FEMA-2021-0024-0001

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