USA - National Wildlife Federation Takes Issue with FEMA's BRIC Program

WASHINGTON, May 15 -- Jessie Ritter, director for water resources and coastal policy of the National Wildlife Federation, 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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On behalf of the National Wildlife Federation, our more than six million members and supporters, and affiliate conservation organizations in 52 states and territories, we write with specific recommendations on the Federal Emergency Management Agency (FEMA) policy related to the Building Resilient Infrastructure and Communities (BRIC) program. For years, the National Wildlife Federation has worked alongside partners to advance fiscally sound, environmentally responsible approaches to natural disaster policy and to improve federal decision making to protect the nation's natural systems and the fish and wildlife that depend on those vital resources. We were supportive of the Disaster Recovery Reform Act of 2018, and in particular Section 1234 which authorized a set-aside for pre-disaster mitigation efforts, resulting in creation of the BRIC program.

The Federation supports FEMA's efforts to develop a BRIC policy and program that will "fund effective and innovative projects that will reduce risk and increase resilience and serve as a catalyst to encourage the whole community to invest in and adopt policies related to mitigation."/1

We appreciate FEMA's commitment to supporting capability and capacity-building for state and local governments and tribes and territories in the program principles. Successful and strategic mitigation requires significant planning, and small, rural and disadvantaged communities in particular often lack the technical knowledge and resources needed to successfully develop, secure funding for, and implement the mitigation activities through BRIC or another source. We also support the BRIC policy's proposed FEMA cost-share of up to 90 percent for mitigation activities in small impoverished communities. Furthermore, we were pleased to see that FEMA has added National Flood Insurance Program (NFIP) participation as an eligibility requirement for all BRIC mitigation projects in the FEMA Special Flood Hazard Area. This is an important criterion to help ensure that NFIP and Stafford Act provisions work in concert.

However, we are concerned that BRIC funding will be available for, and perhaps even prioritize, large and costly structural infrastructure projects (such as levee systems and dams) that can already be funded under other federal programs and which could quickly deplete funds available for more traditional nonstructural mitigation approaches (structure elevation, acquisition/buy-outs, flood-proofing or relocation) which are highly-effective, faster to implement, and provide lasting risk reduction benefits. Based on research after Hurricane Floyd, FEMA found that "acquisition and relocation of flood-prone buildings is more effective in reducing flood losses than any other approach."/2

The BRIC policy should specifically call out floodplain buyouts and restoration as priority actions for reducing flood losses and encourage best practices for implementing buyout programs at the state and local levels. By encouraging mitigation strategies that facilitate strategic (i.e. not checkboard) buyouts and restoration of the most flood-prone properties, FEMA would also be increasing the long-term solvency of the deeply indebted National Flood Insurance Program.

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Read also Building Resilient Infrastructure and Communities (BRIC) - FEMA