Rep. Morelle Issues Public Comment on FEMA Notice

WASHINGTON, May 15 -- Rep. Joseph Morelle, D-New York, 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 8, 2020, and posted on May 13, 2020:

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Thank you for your leadership in the development of the Federal Emergency Management Agency (FEMA)'s new Building Resilient Infrastructure and Communities (BRIC) grant program. As the representative of a community hard hit by annual flooding along the southern shore of Lake Ontario, I am encouraged by the opportunity for serious investment in pre-disaster projects that will allow our communities to better prepare for the next flood, which isn't a question of if, but when. As you finalize the BRIC grant program, I urge you to consider the following recommendations to ensure the program works best for those who will rely on it most.

First, ensure that state and local governments can use BRIC funds for planning, design and early stage activities. It is essential that the BRIC program allows applicants to use funds for project planning, design, and early stage requirements, in addition to project construction. Small or distressed communities are often unable to apply for project construction grants, as they lack the necessary funding to complete the initial project scoping phase. To assist these governments, the BRIC program will allow for funds to be used for project scoping. FEMA should enable and encourage communities to apply for the mitigation planning and pre-development funds necessary to launch a project, as well as for those funds needed to carry out and construct the project.

* Recommendation: FEMA should make project planning and design a category under uses of assistance.

* Recommendation: FEMA should expand the uses of assistance listed in the BRIC policy to include planning, design, and predevelopment activities such as hydrology studies, environmental assessments, vulnerability assessments, architectural and engineering studies, market assessments and economic feasibility studies, site/lease acquisition costs, and permitting.

* Recommendation: FEMA should change the language in the policy to allow for local governments to use BRIC funds for hazard mitigation planning. FEMA should also exempt local governments from the requirement to have a hazard mitigation plan if the applicant plans to use BRIC funds to develop a hazard mitigation plan.

Second, empower states and communities to choose green and natural infrastructure for BRIC projects. States and communities should have the flexibility to choose the infrastructure solutions that work best for their unique needs. FEMA should provide options to employ nature-based solutions and give clear guidance on how to incorporate these techniques into flood mitigation projects under the BRIC program. Natural infrastructure, such as living shorelines or green spaces, can also provide additional benefits such as enhancing outdoor recreation or improving surrounding environments.

* Recommendation: FEMA should expand the uses of assistance listed in the BRIC policy to include nature-based solutions, natural infrastructure and green infrastructure.

* Recommendation: FEMA must improve the BCA to accurately assess nature-based mitigation measures.

Further, engage stakeholders throughout development of the program and communicate necessary information early and clearly. A robust stakeholder process will make BRIC a stronger and more successful program--and it is essential that state and local officials can provide early input and feedback. That said, as states and communities respond to COVID-19, FEMA must provide enough time and as much information as possible early in the process, including the release of guides during the summer 2020 to direct communities on how to prepare applications for fall 2020. In addition, certain BRIC details that are critical to a successful application process--such as example projects, application requirements, and funding levels--remain unknown.

* Recommendation: FEMA should provide early additional guidance on annual program priorities, scoring criteria, compliance procedures, and timeline for application reviews so applicants are able to plan ahead.

* Recommendation: FEMA should engage with local government stakeholders, perhaps through listening sessions, as part of the drafting process associated with detailed rules and policy that will govern grant application criteria, evaluation, and awarding considerations. FEMA also should clarify the rules for the project competition within the BRIC policy and produce additional resources or webinars for applicants as soon as possible.

Finally, set a strong foundation for BRIC by putting the full six percent (6%) set aside towards the program this year, and strive to provide the full 6% in future years. Investing in the resilience of our national infrastructure is not just an urgent priority, it is a smart long-term investment that will create jobs, reinvigorate communities, and save taxpayer dollars.

* Recommendation: FEMA should set aside the full six percent calculated from estimated disaster grant expenditures for the National Public Infrastructure Pre-Disaster Mitigation Fund.

Thank you again for your work to develop FEMA's new BRIC grant program. I am eager to see this program become a reality and I thank you for your consideration of the recommendations laid out in this letter.

Sincerely,

Joseph D. Morelle

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

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