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The following comments are submitted by the
Our comments reflect a series of interviews of coalition partners - experts in housing, resilience, and emergency management, and community members that have lived experience with
In addition to policy and program adjustments, many of these challenges or barriers are reflective of underfunded agency needs.
In the following document, you will find this input organized by the questions posed by
Responses to general questions
Question 1: Barriers - Are there
A lack of emergency and essential services disproportionately affecting vulnerable communities: immediately following Hurricane Sandy, a lack of government response significantly impacted community safety and function. Lost cars, electricity, heat, fuel shortages, and flooded and offline subways meant that many people were unable to get to work to earn income, secure critical medical supplies, or otherwise access daily needs for safety and wellbeing. In
In many areas, disaster response was initially led by volunteers and local non-government organizations that were able to quickly respond due to local knowledge and community trust. In Red
But resources for these organizations are limited. In
"When we have a disaster, these relationships are already formed. Let's do it before the storm...and identify trusted agents," Adams said. "We need to expand our thinking about what a disaster is... [In emergencies], what we're really called to be is community organizers...Sandy came and those people who were barely getting by are now homeless...those are the relationships that are missed because we are viewing disasters as one-offs," he concluded.
Disparities in information access regarding
When interviewed, Coney Island resident and President of Coney Island Beautification Project
Challenges with language access and cultural sensitivity: for many immigrant communities, language and trust in government are barriers to participation. After Hurricane Sandy, there were attempts to provide language access, but there was often a lack of locally-appropriate language interpretation, cultural sensitivity, and depth of knowledge.
The need for local contextual awareness and cultural sensitivity was echoed by a community development and insurance assistance professional. Following Hurricane Sandy, she observed an initial disparity in the number of claims between Canarsie, a predominantly Black and Immigrant neighborhood in which 40% of residents are foreign-born,/2 and wealthier, whiter neighborhoods, leading to an initial perception by
Barriers specific to low-income populations: many residents are uninsured due to insurance costs, preventing quick payouts and the ability to recover financially after repairs drain limited financial resources./3
Even when policies are in place, the periods of time between application submission, approval, and disbursement, respectively, are too long for low-income individuals or entities within the community. Ultimately, funds may cover only temporary repairs. Applications require resources like access to a computer and internet, documents (e.g. social security cards, financial statements), or time off work, all of which can be barriers to low-income, immigrant, and elderly residents. An emergency management policy expert interviewed highlighted that even local governments in impoverished areas have had to take out loans while they wait for
Last, it is important to acknowledge the cascading health effects of
These impacts are disproportionate to low-income and minority communities that are more likely to experience recurrent flooding and do not have the resources to properly clean up after a flood event.
Further, a study in Prehospital and Disaster Medicine found a large negative impact of recurrent flood on mental health outcomes and psychological and physical function, likely related to an erosion of social, environmental, and material circumstances./5
In addition, there is an increase in substance abuse and hospitalizations following flood events, specifically with low-income and minority individuals./6
All of these mental health issues induce costs on the health care system.
Particularly in communities with high populations of people of color, immigrants, and low-income residents:
* Increase the ease of applications and outreach and extend application windows, especially in socially vulnerable communities.
* Increase on-the-ground staff and fund preparedness efforts through locally embedded and trusted community organizations.
* Train technically and culturally competent multi-lingual inspectors and translators or create mechanisms for rapidly funding local organizations to provide these services.
* Increase targeted engagement and awareness-building regarding programs and insurance availability and support in communities. Evaluate innovative strategies to expedite payouts to socially vulnerable individuals and entities, such as parametric policies that automatically pay out a percentage based on a triggering event, to provide some resources until a full inspection (if needed) can take place.
Question 2: Resilience - Are there
Moreover, in addition to not requiring climate resilience,
It was reported that as little as 17% of homes flooded during Hurricane Harvey had flood insurance, many not even in the flood zone. Over the three decades before Harvey, 47% of the flood claims in the region came from properties outside of the 100-year flood zone./9
This flooding outside of the flood zone disproportionately impacted Black and Hispanic communities in the
* Integrate a requirement to consider future climate projections in hazard mitigation grant funding criteria.
* Accelerate the updating of NFIP maps to current and future projections of risk across the country, in accordance with the Biggert-Waters Flood Insurance Reform Act of 2012.
Question 3: Environmental Justice - Are there
See response and recommendations to General Question 1, Barriers.
Pollution disproportionally impacts marginalized communities: additionally, pollution sources and hazardous substance storage are more likely to be located in communities of color and low-income communities. However, these compounding vulnerabilities and impacts are not adequately factored into assistance programs.
The following excerpts from EDF's comments are instructive: ...the BCA for
...Overall, the BRIC program definition [of a small impoverished community] encompasses a very limited number of communities and leaves many underserved communities out. Additionally, tribes are often grouped as one tribal population, even when individual towns or subsets of populations are geographically very rural and separated.
...the benefit-cost ratio (BCR) for
...Natural infrastructure solutions have the potential to offer direct flood risk-reduction benefits as well as co-benefits to underserved communities. However, since [FEMA BCA] methodologies are required to use the 7% discount rate set by OMB Circular A-9412, even substantial benefits in the medium to long run do not enter meaningfully into the BCA.
The BRIC program BCA requires municipalities and states to estimate the value of ecosystem services. These calculations can be difficult and can require the expertise of expensive outside consultants. This could be a hurdle for underserved communities without funding or access to the necessary expertise to estimate potentially significant but hard-to-quantify benefits.
For all of the above reasons, the BCA for
* Develop strategies that address compounding vulnerabilities like pollution sources and hazardous substance storage into assistance programs.
* Adjust the benefit-cost analysis (BCA) for
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Rise to Resilience is a campaign and coalition spearheaded by the
View full comment at: https://downloads.regulations.gov/FEMA-2021-0011-0236/attachment_1.pdf
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1/ Flavelle, Christopher.
2/ New York City Community District Profiles. https://communityprofiles.planning.nyc.gov/
3/ Dixon, L. et al. 2017. The Cost and Affordability of
4/ Bonner, Lynn. "As Mold Grows in the Aftermath of Hurricanes, More NC Asthma Patients Suffer."
5/ Wind, T.,
6/ Moise IK, Ruiz MO. Hospitalizations for Substance Abuse Disorders Before and After Hurricane Katrina: Spatial Clustering and Area-Level Predictors,
7/ Frank, Thomas. "EXTREME WEATHER: IG: FEMA Never Followed 20-Year-Old Disaster Law." EXTREME WEATHER: IG: FEMA Never Followed 20-Year-Old Disaster Law --
8/ FEMA Needs to Improve Management of Its Flood Mapping Programs.
9/ Highfield, Wesley E, et al. "Examining the 100-Year Floodplain as a Metric of Risk, Loss, and Household Adjustment."
10/ Smiley, Kevin T. "Social Inequalities in Flooding inside and Outside of Floodplains during Hurricane Harvey." Environmental Research Letters,
11/ Emergency Planning and Community Right-to-Know Act (EPCRA).
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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0011-0001
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