Land Trust Alliance Issues Public Comment on FEMA Notice

WASHINGTON, July 28 -- Lori Faeth, senior director of government relations at the Land Trust Alliance, has issued a public comment on the Federal Emergency Management Agency notice entitled "Request for Information on FEMA Programs, Regulations, and Policies". The comment was written and posted on July 21, 2021:

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Thank you for seeking public input on ways to bolster climate resilience and environmental justice in existing FEMA programs, regulations and policies. The Land Trust Alliance appreciates the opportunity to submit comments in response to your inquiry.

Founded in 1982, the Land Trust Alliance (Alliance) is a nonprofit corporation and national land conservation organization based in Washington, D.C., that works to save the places people need and love by strengthening land conservation across America. The Alliance represents nearly 1,000 member land trusts. Alongside our members, we harness three fundamental aspects of the American ethos: volunteerism, community spirit and connection to the land.

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 $7 saved for every $1 invested./1

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 FEMA to engage land trusts more substantially as partners in hazard mitigation for climate resilience.

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 FEMA grant programs to better account for all cobenefits of natural infrastructure. Natural infrastructure can save up to $7 for every $1 invested when compared to traditional, gray infrastructure.1 Implementing natural infrastructure additionally often provides co-benefits such as wildlife habitat, increased drinking water quality, recreational opportunities and carbon sequestration, which helps to mitigate the impacts of climate change. These co-benefits, however, are often difficult to empirically measure. For example, land conservation in riparian areas can significantly decrease the risk and amount of flood damage to nearby communities.

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. FEMA could also consider setting aside a portion of mitigation assistance funds solely for natural or green infrastructure projects.

* Reducing complexity and response time for all FEMA grant programs. Many municipalities, particularly those most vulnerable to disasters, do not have the resources or capacity to undertake the complex and time-consuming application process for FEMA grants. Delays in funding for FEMA grants also present a serious issue.

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 FEMA direct more funds and additional staff toward assisting socially disadvantaged communities in accessing its public assistance programs.

* 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 Building Resilient Infrastructure and Communities grant program to better reach disadvantaged communities. This could include expanding the definition of "small, impoverished communities" to include tribal communities and other slightly larger communities that have historically been underserved; increasing the federal cost-share to 100% for these communities;

dedicating staff at FEMA headquarters or regional offices to assist under-resourced communities in the application process; adding additional funds that allow the program to broaden its focus from coastal flooding to preparing communities for inland flooding and wildfire; and reducing the maximum amount of funds available for individual projects to ameliorate the "winner takes all" outcomes and more equitably distribute mitigation funds. Additionally, land trusts and other community planning organizations often provide technical assistance to municipalities applying for mitigation assistance grants and could, if given federal resources, expand this work to reach those communities most in need. Providing pre-application planning grants for historically underserved communities could also help to address the inequities exacerbated by the technical complexity of the grant application process.

We applaud FEMA's efforts to seek public input and resolve sustained issues of inequity within the administration of its programs. We look forward to continuing a dialogue on how the land trust community can play a larger role in disaster mitigation and response to increase climate resilience.

Sincerely,

Lori Faeth

Senior Director of Government Relations

Land Trust Alliance

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Footnotes:

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 Gulf Coast of the United States. PLOS ONE 13(4): e0192132. https://doi.org/10.1371/journal.pone.0192132

2/ Shepard C, Majka D, Brody S, Highfield W, and J Fargione. Protecting Open Space & Ourselves: Reducing Flood Risk in the Gulf of Mexico Through Strategic Land Conservation. Washington DC: The Nature Conservancy. December 2016.

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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0011-0001

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