Wetlands Watch Issues Public Comment on FEMA Notice

WASHINGTON, May 16 -- William "Skip" Stiles Jr., executive director of Wetlands Watch Inc., Norfolk, Virginia, 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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Wetlands Watch is a nonprofit based in Norfolk, Virginia, that works to conserve and protect wetlands by offering solutions to tidal wetlands' largest threat, sea level rise. We work with local government staff to promote sea level rise adaptation. A significant portion of this work occurs through our organization's floodplain management program, in which we focus extensively on FEMA programs, most notably the National Flood Insurance Program, the Community Rating System (CRS), and Hazard Mitigation Grant assistance programs. Two of our staff are Certified Floodplain Managers (CFM), one of whom also Chairs the Coastal Virginia CRS Workgroup and serves on Board of the Virginia Floodplain Management Association.

Wetlands Watch recognizes the essential roles pre-disaster planning and project implementation play in helping protect communities and regions against the physical and economic risks of increased flooding. The Building Resilient Infrastructure and Communities (BRIC) program offers an opportunity for our federal government to invest resources reflective of the need, as demonstrated through post-storm disaster assistance. We hope the BRIC Program will incorporate the comments from organizations and individuals like Wetlands Watch that work with the local government staff who will apply for this greatly needed funding and execute the resulting projects.

Building Resilient Infrastructure and Communities Policy (the Policy) section 1234 of the Disaster Recovery Reform Act (DRRA) simply "authorizes FEMA to set aside 6 percent of estimated disaster expenses for each major disaster" to fund the BRIC program, but does not require a full 6 percent annual distribution or specific a minimum percent distribution (emphasis added). The policy indicates that "FEMA will calculate the 6 percent set aside within 180 days after each major disaster," but again, there is no requirement that the money generated by the 6 percent allocation is spent in full or even in part. The policy should mandate that FEMA distribute the full 6 percent of disaster spending to the BRIC funding program annually.

Wetlands Watch supports each of the BRIC guiding principles delineated in the Policy. Three principles are of particular interest to our organization: "support communities through capability and capacity building," "encourage and enable innovation," and "provide consistency."

BRIC must support capacity and capability building at the local level. As well summarized in Chapter 2 of the 'Summary of Stakeholder Feedback Report: Information Sheet,' this support is critical for the communities who lag behind others in resilience planning. In our extensive time working with local governments in Virginia, Wetlands Watch has found that many local governments lack the basic resources and time to simply think about how to build resilience in the community, which may include sending a staff person to receive basic floodplain and/or emergency management training. The BRIC program could allow communities to develop a resilience program from a strong foundation of knowledge and experience, a process currently unavailable in underserved communities. Communities cannot responsibly enter the project implementation phase until this foundational thinking, capacity, and capability building occurs.

BRIC must encourage and enable innovation in its project funding. Approving and even prioritizing projects that offer an alternative approach to flood control will help communities think creatively and could result in new best practices currently unknown to practitioners. FEMA's grant programs are notoriously rigid, which discourages creative project applications. FEMA funding for disaster mitigation is often the only funding option known to communities. Offering an opportunity to broaden the scope of projects funded could introduce new concepts of flood mitigation to communities who rely exclusively on FEMA grant programs for information about reducing the risks of flooding. The BRIC program should also encourage innovation through the prioritization of nature-based solutions to disaster mitigation. Chapter 1 of the 'Summary of Stakeholder Feedback Report: Information Sheet' captures our concerns that natural infrastructure must be an integral part of the BRIC program. Nature-based projects always provide multiple-benefits and should be weighted accordingly in the project application process. Finally, BRIC should require that all project applications account for and accommodate future conditions. Depending on the project region, future conditions could include sea level rise, land subsidence, and/or increased rainfall. Innovative projects are long-lasting projects.

BRIC must require consistency with local, regional, and state plans, standards, and policies in its funded projects. BRIC should require that all projects follow local, region, and/or state adopted higher flood safety standards and sea level rise planning scenarios. All projects should also be consistent with all local, regional, and/or state adopted floodplain management, emergency management, green infrastructure, and other relevant planning documents. At a minimum, the inclusion of future conditions in a project should be a weighted factor in the application process.

Wetland Watch encourages FEMA to carry over elements of the existing the Pre-Disaster Mitigation (PDM) Program into BRIC. Specifically, Community Rating System (CRS) Program participation and class rating should continue to be a weighted factor in the application process. BRIC funding should also be available for the creation of local and/or regional Hazard Mitigation Planning documents. The project benefit cost analysis should continue to apply the ecosystem service matrix and consider updating it to include more benefits, such as life-cycle cost, mitigation opportunity, and wetlands migration.

We look forward to the implementation of BRIC and appreciate the intention to strengthen pre-disaster mitigation in our communities.

Sincerely,

William "Skip" Stiles, Jr.

Executive Director

Wetlands Watch, Inc.

2601 Granby Street

Norfolk, VA 23517

[email protected]

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

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