Higher Ground Network Issues Public Comment on FEMA Notice

WASHINGTON, Nov. 17 -- The Higher Ground Network 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. 15, 2021:

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The impacts of rising sea levels, warmer waters, eroding wetlands and other climate-related events are all too obvious in the Gulf South, especially during Hurricane season. For two years in a row, Louisiana has been hit by storms (Hurricanes Laura 2020 and Ida 2021) with 150 mph winds. These catastrophic storms are the mark of climate degradation and will only worsen if we don't implement plans to reduce carbon emissions immediately. This means more frequent and intense storms for the region. Simple rain events here in New Orleans often lead to flooding in vehicles and in homes.

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

Question 1 - "cumulative substantial damage"

Target FEMA financial support for buyouts and elevation to low-income residents whose homes flood repetitively. Be flexible in the way that you determine whether or not residents have flooded repetitively.

Question 3 - "critical infrastructure"

Prohibit all construction within the 100-year floodplain.

Require that all critical infrastructure (schools, hospitals, etc.) in the 500-year floodplain be elevated.

Ban all industry -- including steel manufacturer, factory farming, mining, oil refineries, and chemical plants - in the 500-year floodplain.

Question 5 - "repeatedly flooded properties and managed retreat"

Increase NFIP funds to $100,000 for mitigation measures through the Increased Cost of Compliance.

Make buyouts attractive to homeowners by recognizing the cost of moving to desirable areas, far from flooding, pollution, or other hazards. Remove the cost-share requirement for low-income communities.

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

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