Refuge Resource Group Issues Public Comment on FEMA Notice

WASHINGTON, May 16 -- J. Adam Riggsbee, president of the Refuge Resource Group, Austin, Texas, 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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Please accept the following comments regarding FEMA's forthcoming guidance relating to the use of funds from the Building Resilient Infrastructure and Communities program. In addition to the brief comments provided in this letter, we have appended a white paper detailing a proposed public-private partnership (P3) model for floodplain buyouts that we believe can greatly improve administrative efficiencies and programmatic efficacy. The Refuge Resource Group (RRG) is a company recently formed by environmental entrepreneurs to develop and implement the P3 floodplain-buyout model described in the appended white paper.

RRG has met to discuss ideas presented in this letter and the attached white paper with various agencies, legislators and administrative representatives in Washington D.C. and various states affected by hurricane-induced flooding--North Carolina and Texas in particular. Agency meetings have included the Department of Housing and Urban Development (HUD), the Federal Emergency Management Administration (FEMA), the North Carolina Office of Recovery and Resiliency (NCORR) and the General Land Office of Texas. Specifically, within FEMA we met with Ryan Janda and Ancuta Lungu; we found both to be knowledgeable, engaging and supportive (conceptually) of P3 approaches to floodplain buyouts.

While all flood mitigation strategies represent favorable cost benefit ratios,/1 only buyouts can permanently eliminate a structure's future flood risk. As discussed in our previous meeting with Mr. Janda and Ms. Lungu, RRG believes the proposed P3 approach can greatly improve administrative efficiencies and overall programmatic efficacy for strategic buyouts. Recent research has demonstrated that: a) government administrated buyout programs are too protracted to meet the needs of affected citizens;/2 and b) buyout programs have become less efficient over time./3

Given the scale of the National Flood Insurance Program's actuarial problems/4 and the recent increased frequency and severity of hurricane-related flooding,/5 more efficient buyout programs are imperative for affected citizens and the nation's taxpayers.

While FEMA and various states have recently developed strategies to expedite the deployment of federal disaster funds, the need to more rapidly deliver mitigation aid to affected citizens remains particularly acute. And research suggests the longer buyouts are delayed, the more likely people are to repair and reoccupy homes, remaining at risk for future flooding./1

The P3 approach proposed by RRG can assist state and local governments in administrating strategic buyouts, at our risk, delivering more money faster to citizens in the most need while saving limited federal funds. BRIC funding decisions should therefore prioritize buyouts--especially those utilizing P3 approaches--over other mitigation strategies.

We appreciate your consideration of our comments and the appended white paper describing the proposed P3 buyout concept. We look forward to further engagement by FEMA regarding this concept. We believe the private sector has much to offer the nation's citizens as they attempt to recover and avoid future losses and hardships associated with hurricane-related flooding.

View attachment at: https://www.regulations.gov/contentStreamer?documentId=FEMA-2019-0018-0143&attachmentNumber=1&contentType=pdf

Sincerely,

J. Adam Riggsbee

President

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Footnotes:

1/ Multi-Hazard Mitigation Council (2019). Natural Hazard Mitigation Saves: 2019 Report. National Institute of Building Sciences. Washington, D.C.

2/ Weber, A. and R. Moore. 2019. Going Under: Long Wait Times for Post-Flood Buyouts Leave Homeowners Under Water. Natural Resouces Defense Council. September 2019; R: 19-08-A.

3/ Mach, K.J, C.M. Kraan, M. Hino, A.R. Siders, E.M. Johnston and C.B. Field. 2019. Managed retreat through voluntary buyouts of flood-prone properties. Science Advances 2019; 5: eaax8995.

4/ GAO. 2017. High Risk List. Available on the World Wide Web here.

5/ Paerl, H, N.S. Hall, A.G. Hounshell, R.A. Luettich Jr., K.L. Rossignol, C.L. Osburn and J. Bales. 2019. Recent increase in catastrophic tropical cyclone flooding in coastal North Carolina, USA: Long-term observations suggest a regime change. Scientific Reports 9:10620

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

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