National Ready Mixed Concrete Association Issues Public Comment on FEMA Notice

WASHINGTON, May 16 -- Andrew Tyrrell, executive vice president for government affairs at the National Ready Mixed Concrete Association, Alexandria, Virginia, 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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The National Ready Mixed Concrete Association (NRMCA) represents more than 1700 companies and subsidiaries and employs more than 125,000 American workers who manufacture and deliver ready mixed concrete. NRMCA represents both national and multinational companies that operate throughout every state with more than 70,000 ready mixed concrete trucks and upwards of 6,000 ready mixed concrete plants. Approximately 85% of the ready mixed concrete industry is comprised of family-owned and operated small businesses intimately affiliated with their communities.

Ready mixed concrete companies produce a construction material vital to our built environment. From roads to bridges, to homes and high-rises, our built environment could not be realized without the use of ready mixed concrete. This important building material is created by combining fine and coarse aggregates, cement and water. In 2019 alone, the ready mixed concrete industry is estimated to have produced more than 460 million cubic yards of ready mixed concrete, representing more than $100 billion in economic activity. Virtually every residential, commercial and public works project in America uses at least some ready mixed concrete.

NRMCA strongly supported the Disaster Reform and Recovery Act of 2018 and continues to support the Federal Emergency Management's efforts to foster a national culture of preparedness. Enhancing the resilience of our communities by mitigating the impacts of natural and man-made disaster, sea level rise and climate change must be a priority.

NRMCA makes the following comments on FEMA's Proposed Policy on the Building Resilient Infrastructure and Communities Program. In addition, NRMCA supports and associates itself with the comments of the BuildStrong Coalition and the International Code Council.

1. The program should continue to focus on enhancing resilience and incentivizing resilient construction of mitigation infrastructure.

The need for resilience and the ability to withstand natural disaster is the underlying concern of the BRIC program. Resilience is the ability to withstand the effects of natural and man-made disaster that allows the structure to continue to provide its primary functions, minimizes the time required to return to normal operating status, and has the capacity to recover and withstand a potentially disruptive event.

The projects implemented by state and local governments, tribes and territories to reduce the risks posed by natural hazards should seek to meet this standard of resilience in seeking to eliminate or minimize the duration of impact of a natural disaster.

2. Projects should maintain a material neutrality through performance based specifications.

As FEMA works to support communities' resilience, NRMCA urges that project decisions be made on the basis of the project's mitigation potential rather than the materials utilized to achieve the mitigation. Performance based specifications rather than prescription based specifications will best achieve the resilience the program seeks to foster. Further, the benefit-cost analysis should consider the full life of the project and account for the for repair, rebuilding and ultimate replacement of the asset.

3. Public private partnerships should be eligible to provide the non-federal share of project funding.

NRMCA encourages FEMA to allow applicants to fund the non-federal share of the project through public-private partnerships and other innovative financing and funding mechanisms.

4. Incentivize the adoption and enforcement of strong building codes and standards and policies that incentivize strong building codes.

Strong building codes and enhanced construction have consistently proven to be effective bulwarks against the ravages of natural disasters. Investment in mitigation through building codes has repeatedly been shown to yield savings. NRMCA strongly supports the adoption and enforcement of strong and enhanced building codes, as well as policies that incentivize property owners to build to stronger standards. Policies like the Disaster Savings and Resilient Construction Act that provide a tax credit to property owners who rebuild after a natural disaster using resilient construction techniques incentivize home and business owners to prepare for future disasters.

NRMCA encourages FEMA to make the adoption and enforcement of strong and resilient building codes a consideration in awarding projects, both as an eligible grant activity and a consideration for grants for other resilience or mitigation projects. This will incentivize applicants to adopt and enforce strong building codes to enhance their application for BRIC grants.

5. Funding should be made available to improve the resilience of affordable housing.

Applicants should be able to access grant funding to cover any delta between standard construction and resilient construction for affordable housing, allowing affordable housing to be built to both building and energy standards that will enhance the sustainability and resilience of the structures.

Submitted May 11, 2020.

Andrew Tyrrell

Executive Vice President, Government Affairs

National Ready Mixed Concrete Association

66 Canal Center Plaza

Suite 200

Alexandria, VA 22314

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

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