University of Minnesota Issue Public Comment on FEMA Notice
The comment was co-signed by Maysa Alquaisi,
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We are a group of four law students currently enrolled in an environmental law course at the
* Mitigation as a means to reduce, rather than exacerbate, economic and racial inequity (Q5, Q11)
* Changes to Floodplain Management which encourage working work with, rather than fighting, natural ecosystems, including habitat protection for threatened and endangered species (Q12, Q4, Q17, Q7, Q6)
* Changes to the state-level mitigation planning process to include more voices from the community (Q18)
A) Mitigation Should be a Means to Reduce, Rather than Exacerbate, Economic and Racial Inequity.
(Q5) Funds for managed retreat should be directed 1) to communities and individuals who cannot afford to accomplish managed retreat on their own, and/or 2) individuals and communities situated in risky areas who cannot afford to implement mitigation strategies to lower their flood insurance rates. While
Discontinuing flood insurance for repetitive loss properties also disproportionately affects BIPOC individuals and families, as well as those near the poverty line who have no option but to rebuild in the same location. If a community contains repetitive loss properties, those properties are devalued, their owners have lost equity in their homes, the community loses its tax base, and the community shrinks. Targeted funding should therefore be provided for managed retreat to compensate the most at-need individuals to begin a life in a less risky home of their choosing, and so communities can rebuild in a way that makes the most sense for them. By targeting lower income individuals and families for managed retreat, this would also increase the likelihood of taxpayer dollars going directly to those in need of assistance, rather than corporations and landlords who profit off simply rebuilding properties in flood-prone areas rather than utilizing proper mitigation methods. This is a matter of reducing economic inequality after a disaster, as well as an environmental imperative for communities blighted by these properties.
Like many other forms of insurance, the NFIP requires available funds for an individual or family to be able to contribute and receive benefits. If an individual or family cannot pay the NFIP rates, they will be forced to opt out of insuring their property against flooding. Without the NFIP, any damage to their property incurred during a natural disaster will fall on
Lastly, (Q11) there should absolutely be a universal affirmative obligation on the part of sellers and/or lessors of residential properties to disclose information about flood risk to prospective buyers or lessees. As
B) Changes to Floodplain Management which encourage working with, rather than fighting, natural ecosystems, including protecting the habitats of threatened and endangered species
First, (Q12)
Second, we believe that
We believe
C) (Q18) Changes to the State-level Mitigation Planning Process Should Include More Voices from the Community
As of the 2015 release of
However, for
One effective way to solicit the voices of these communities is having a notice and comment period for mitigation plans that are pending review from
The state's role in community planning should not just be a managerial one. The states should listen to the needs and concerns of these communities, then it can enact the mitigation plan that would directly affect these same communities.
In conclusion, we hope to see changes to the program which better serve the goals of environmental and economic justice for the entire community.
Thank you for considering our comments.
Maysa Alquaisi,
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The notice can be viewed at https://www.regulations.gov/document/FEMA-2021-0024-0001
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