Lone Star Legal Aid Issues Public Comment on FEMA Notice
WASHINGTON,
The comment was co-signed by
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I. INTRODUCTION
On behalf of the respective clients identified below and each group's represented community,
LSLA's mission is to protect and advance the civil legal rights of millions of Texans living in poverty across LSLA's service area by providing these individuals, their families, and their communities free advocacy, legal representation, and community education to further equal access to justice, including supporting their right to participate in our nation's democratic processes--such as this
LSLA's service area includes seven coastal counties on the upper
The following sections describe LSLA's clients (Commenters) who have worked closely with LSLA to produce these comments. The Community Profiles detailed in Part II of these comments describe LSLA clients' collective experiences and informs the answers to
II. REPRESENTED COMMUNITIES ON THE
A. COMMUNITY PROFILE: INDEPENDENCE HEIGHTS REDEVELOPMENT COUNCIL,
1. Overview of
2. Demographics of
IHRC represents the neighborhood of
Figure 1: Environmental Justice Profile based on Demographic Index from EJ Screen of
Link to figure below.
The Demographic Index in EJSCREEN is a combination of percent low-income and percent minority, the two demographic factors that were explicitly named in Executive Order 12898 on Environmental Justice. For each Census block group, these two numbers are simply averaged together. The formula is as follows: Demographic Index = (% minority + % low-income)/2./1
All of the properties in
Figure 2: Footprint of
Link to figure below.
The boundaries of the original town of
Based on the 2010
Possibly buoyed by
As a result of its first citizens' tenacity and resilience,
This achievement and the subsequent growth of this community deserves recognition because people of African descent were able to purchase and own land in segregated
The establishment of
B. INDEPENDENCE HEIGHTS' EXPERIENCE WITH DISASTERS
From the original failure by the
These conditions have left the
The racial wealth gap in this country is exemplified by communities like
Figures 3 and 4: Distribution of Properties Impacted by Hurricane Harvey in
Link to figure below.
Tropical Storm Imelda, the 5th wettest tropical cyclone in the continental
For low-income Black and Latino communities, even a medium-sized storm can spell disaster on top of the ongoing burden of structural racial inequality. A study by
Even after 8 federally declared major disasters in
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In addition to developing progressive premium structures and utilizing mitigation strategies,
Relatedly,
View full comment and figures at: https://downloads.regulations.gov/FEMA-2021-0011-0245/attachment_1.pdf
Respectfully submitted,
ENVIRONMENTAL
COMMUNITY ADVOCACY TEAM
DISASTER RELIEF UNIT
Shrushti Kothari ([email protected]), Staff Attorney
P.O. Box 398
Telephone: 713-652-0077
Facsimile: 713-652-3141
ATTORNEYS FOR SUPER NEIGHBORHOOD 49&50, INDEPENDENCE HEIGHTS REDEVELOPMENT COUNCIL, SUPER NEIGHRBORHOOD 48, AND
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Footnotes:
1/ Calculated from the
2/ Handbook of Texas Online,
3/
4/ Handbook of Texas Online,
5/ See description of Booker T's Towns, performed in 2018, https://tockify.com/al200/detail/283/1520434800000
6/ Handbook of Texas Online,
7/ Id.
8/ 8 Flood Factor data for
9/
10/
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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0011-0001
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