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Thank you for seeking public input on ways to bolster climate resilience and environmental justice in existing
Founded in 1982, the
Land trusts play a significant role both in mitigating the threat of climate change and in helping our natural and human systems adapt to a changing climate. As the atmosphere warms, experts project an increase in frequency and severity of natural disasters, sea level rise and changes in precipitation patterns. Communities and ecosystems across the country are already experiencing the effects of our changing climate, particularly as evidenced by last year's unprecedented wildfire and hurricane season. As these impacts worsen, land trusts will play an increasingly vital role in fostering the resiliency of both our natural habitats and the communities that depend upon them.
Land trusts have the tools and expertise to protect natural resources that are economically important and protect our communities from natural disasters. They have long been key players in coastal and floodplain management by maintaining and restoring the natural functions of these ecosystems. Taking these steps helps protect communities from high winds, increased storm surges and flooding. Natural infrastructure, such as wetlands and living shorelines, can provide a more resilient, cost-effective approach to mitigating the risk associated with natural disasters than traditional gray infrastructure, with an estimated
Open space is one highly effective form of natural infrastructure,/2 and land trusts are well practiced in selecting and managing the most critical open space for both community and habitat resilience. As trusted community members and experts in land transactions, land trusts are poised to expand this work to partner with states and municipalities in voluntary buyout programs. Doing so will secure more resilient open space in critical ecosystems such as floodplains and coastal areas.
In addition to the mitigation activities that many land trusts perform, some land trusts have played an important role in assisting communities recovering from natural disasters. In these moments of crisis, land trusts have provided information, shelter or resources and assisted with cleanup and restoration of damaged natural systems. Moreover, countless land trusts have become leaders in climate resilience for their communities by lending their expertise in land stewardship to assist in regional adaptation planning efforts.
Preparing for climate change will require localized approaches informed by expert practitioners. If given a seat at the table, land trusts can serve in this role. For these reasons, we urge
Specifically, we recommend:
* Updating the Hazard Mitigation Assistance Grant programs to allow land trusts to be eligible applicants. Land trusts are already engaged in work to build climate resilience, including open space preservation, habitat restoration, land-use planning and other natural infrastructure projects. Engaging this community of experts for disaster mitigation and response would help ensure that interventions are localized and more equitable.
* Enabling land trusts to participate more explicitly in voluntary floodplain buyout programs, including the ability to hold land titles and easements. Land trusts are well integrated with communities, have expertise in land transactions and stewardship, and can mobilize resources faster and more flexibly than the federal government. If engaged as formal partners in buyout programs, they can bring a more localized and, often, more equitable approach to these programs. Moreover, as experts in land stewardship, land trusts can ensure that buyout properties do not become vacant mowed lots, but instead function in a way that increases community resilience.
* Updating cost-benefit analyses in
However, it is typically cost-prohibitive to perform the types of analyses necessary to quantify the avoided damage. This can result in natural infrastructure for flood mitigation being significantly undervalued in cost-benefit analyses for grant awards. To overcome this, projects that include natural infrastructure should be given more weight in the benefit cost analysis.
* Reducing complexity and response time for all
For example, many homeowners interested in participating in voluntary buyout programs ultimately decide the wait time for funding is too long and decline to participate. This is especially true for lower-income residents who lack the resources to relocate before federal funding comes through and may be forced instead to invest in renovation and repair of damaged property in the wake of disaster. We recommend that
* Decreasing complexity and administrative burden of the Community Rating System of the National Flood Insurance Program. This would encourage more municipalities, particularly those with less capacity and resources, to enroll and take actions to reduce their communities' flood risk, such as protecting and restoring open space. Additionally, the CRS program should be structured in a way that incentivizes communities to take new, additional actions for flood-risk reduction to ensure the best investment of taxpayer funds in disaster mitigation.
* Implementing measures in the
dedicating staff at
Senior Director of Government Relations
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1/ Reguero BG, Beck MW, Bresch DN, Calil J, Meliane I (2018) Comparing the cost effectiveness of nature-based and coastal adaptation: A case study from the
2/ Shepard C, Majka D, Brody S, Highfield W, and J Fargione. Protecting Open Space & Ourselves: Reducing
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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0011-0001
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