Residents Against Flooding Issues Public Comment on FEMA Notice

WASHINGTON, Nov. 20 -- Roger Gingell, chair of the Residents Against Flooding, Houston, Texas, has issued a public comment on the Federal Emergency Management Agency notice entitled "Request for Information on the National Flood Insurance Program's Floodplain Management Standards for Land Management and Use, and an Assessment of the Program's Impact on Threatened and Endangered Species and Their Habitats". The comment was posted on Nov. 16, 2021:

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I am writing as the Chair of Residents Against Flooding (Houston, Texas) and as the former owner of a home that flooded due to very poor regulations on construction by the city of Houston. See my answers below:

Question 1 - "cumulative substantial damage"

Target FEMA financial support for buyouts and elevation to low-income residents whose homes flood repetitively. Be flexible in the way that you determine whether or not residents have flooded repetitively.

Question 3 - "critical infrastructure"

Prohibit all construction within the 100-year floodplain.

Require that all NEW critical infrastructure (schools, hospitals, etc.) in the 500-year floodplain be elevated.

Question 5 - "repeatedly flooded properties and managed retreat"

Increase NFIP funds to $100,000 for mitigation measures through the Increased Cost of Compliance.

Make buyouts attractive to homeowners by recognizing the cost of moving to desirable areas, far from flooding, pollution, or other hazards. Remove the cost-share requirement for low-income communities.

Question 6 - "endangered species"

Protect endangered species by prohibiting all construction in flood prone areas, thus giving greater protection to wetlands. WETLANDS ARE IMPORTANT FLOOD MITIGATION RESOURCES.

Question 7 - "increase resilience to flooding"

Prohibit all construction within the 100-year floodplain and prohibit the use of fill in the 500-year floodplain.

Question 9 - "enforcement"

Improve monitoring, tracking, and public disclosure of community compliance with NFIP requirements. Find ways to help communities comply.

Question 11 - "disclosure"

Ensure that new home owners can find out about flood risks by requiring states to pass disclosure laws.

Question 12 - "accounting for climate change" Ensure that FEMA flood maps, modeling and calculations take account of climate change.

Take account of future development and land use change when creating and updating maps. I AM PARTICULARLY CONCERNED ABOUT INCREASED TEMPERATURES IN THE GULF OF MEXICO GENERATING STRONGER HURRICANES AND TROPICAL STORMS (SEE HURRICANE HARVEY).

Question 17 - "prohibit fill and build"

Prohibit the use of fill in the 500-year floodplain. THIS IS A MAJOR CAUSE OF FLOODING IN HOUSTON, TEXAS Roger Gingell

Chair, Residents Against Flooding

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The notice can be viewed at https://www.regulations.gov/document/FEMA-2021-0024-0001

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