International Association of Structural Movers Issues Public Comment on FEMA Notice

WASHINGTON, May 16 -- Tammie DeVooght Blaney, executive director of the International Association of Structural Movers, Neenah, Wisconsin, 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 on May 11, 2020, and posted on May 13, 2020:

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International Association of Structural Movers (IASM) welcomes this opportunity to provide comments on the proposed policy for the new BRIC program.

Non-structural flood hazard mitigation projects of elevation and dry flood proofing are proven methods of reducing flood risk. Over the last decade increased levels of the HMA/FMA and HMGP post-disaster funds have been focusing on drainage projects after flooding. This has reduced the numbers of elevations and dry flood proofing projects for buildings. There has been no requirement that infrastructure projects actually take pre-FIRM buildings out of the 1% - 100 year flood zone and the mandatory flood insurance requirements for mortgaged properties. Building flooding is very different from damaged infrastructure and drainage systems.

IASM is considerably concerned by the overall program description in Activity Eligibility Criteria that does not include any apparent prioritization of traditional, non-structural flood reduction measures such as structure elevation, acquisition, flood-proofing or relocation. We are in the middle of a broad scale re-adjustment to actuarial from subsidized policy premium rates on millions of pre-FIRM high flood risk buildings. This has increased the need for funding for elevation and relocation, especially on low to moderate income family homes.

FEMA should make a clear statement about the use of the funds, with the intention that other funded federal agencies cannot use the BRIC funds for their projects.

IASM is concerned that BRIC funding will be available for large and costly infrastructure projects that can already be funded under other federal programs. Huge levee systems or dams should never be funded by BRIC. If this happens, there will be less funding for the traditional non-structural projects which are highly effective, faster to implement, and provide lasting risk reduction.

When considering Activity Eligible Criteria, in addition to the current policy, IASM would like to see grant applications including in the cost of acquisition projects a variety of variables that currently are ignored but cause permanent economic and other damage to communities including:

1. Cost to maintain landfills and environmental costs of toxic waste

2. Loss of property tax base to communities on a per building basis, other financial losses based on individual properties such as school aid for K-12 schools and aid to technical colleges and others

3. Social impacts to communities that lose affordable housing when they already have a housing shortage

With COVID 19 now wreaking major havoc on all US communities, every factor that could detrimentally impact communities' financial health must be evaluated. The positive tax impact on communities when homes are elevated or relocated, should be the priority over acquisition in most cases to preserve communities' vital tax base.

The criteria should support Planned/Managed Retreat projects which relocate buildings. IASM recommends increased support for managed retreat projects. These are among the most complicated of all mitigation projects because various federal and state agencies are involved to support planning/relocating infrastructure, homes, and businesses. This is why very few community relocations have actually happened. It is clear that retreating from some areas is the best long-term option. IASM recommends that BRIC guidance include a section on supporting these types of projects. FEMA could use its recent experience helping Newtok, Alaska, Shell Lake, Wisconsin or the historic relocations in Missouri. Planning and project implementation work should be allowed under BRIC as long as tangible results are demonstrated with each proposed application.

IASM thanks FEMA for the opportunity to share our feedback on the BRIC program.

Sincerely,

Tammie DeVooght Blaney

Executive Director

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

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