12 Apr Adaptation Working Group Infrastructure Letter in Infrastructure
March 31, 2021
|The Honorable Charles Schumer Majority Leader U.S. Senate Washington, D.C. 20510
|The Honorable Nancy Pelosi Speaker U.S. House of Representatives Washington, D.C. 20515
|The Honorable Mitch McConnell Minority Leader U.S. Senate Washington, D.C. 20510
|The Honorable Kevin McCarthy Minority Leader U.S. House of Representatives Washington, D.C. 20515
Dear Leader Schumer, Minority Leader McConnell, Speaker Pelosi, and Minority Leader McCarthy:
As our communities face unprecedented challenges brought about by COVID-19 and economic recession, we are writing on behalf of the Adaptation Working Group to thank you for your actions to date and your leadership in advancing comprehensive infrastructure legislation. We are a coalition of national organizations representing a broad array of stakeholders – from conservation groups to local governments to utilities to underserved populations and more – who believe that promoting adaptation to flooding and community resilience should be a federal priority.
As Congress identifies investments that create jobs and strengthen our economy, it is critical to move beyond business-as-usual by supporting infrastructure programs that build resilience to flooding and promote equity. Prior to COVID-19, our nation was in the midst of its largest ever cumulative disaster recovery effort, with catastrophic disasters reaching every corner of the country over the last four years and flooding accounting for the vast majority of damages. The first step to building resilience in our communities is building infrastructure that can withstand disasters.
Research shows that every $1 billion spent on flood resilient infrastructure can create 40,000 jobs. Such investments are especially critical in underserved communities which, as recent hurricane seasons demonstrate, often bear the brunt of flooding and face longer recovery times. Much-needed investments in resilient infrastructure can spur economic growth and give underserved communities the tools needed for long-term recovery and resilience.
As Congress considers comprehensive infrastructure legislation, we encourage you to prioritize the following programs, which will not only build resilience and strengthen our national infrastructure, but enable communities to adapt to flooding and other natural disasters and boost local economies.
Federal Emergency Management Agency
Building Resilient Infrastructure and Communities
- Continued investment should be directed toward FEMA’s Building Resilient Infrastructure and Communities (BRIC) program, which is currently funded by a set aside of up to 6 percent of disaster relief expenditures. Based on FEMA’s understanding of community demand for this program and the dollar-value of proposals submitted in its first year, significant investments should be made to ensure that it sufficiently meets the needs of disaster-affected communities. With that in mind, it should be funded at the full 6 percent level.
- Additionally, FEMA should consider setting aside a portion of that funding for nature-based approaches.
- As FEMA learns from BRIC’s inaugural year and makes its first set of funding decisions, increased transparency about the program is needed. Specifically, communities would benefit from the following information:
- Details about the amount of total funding available versus funding awarded
- Summary learnings from the first year of grants:
- Number of applications received vs. number of projects awarded
- Summary of types of projects funded and information on what projects included nature-based approaches
- Details on how project applications were scored, types of projects that were awarded, and what criteria made applications competitive
- Details about how technical assistance is applied and provided
- Details about the size of communities that applied for funding as well as those that successfully received funding
- Guidance on partnerships, including any case studies or best practices from the first round of grants
- To enable more equitable distribution of funds, FEMA should identify and fund technical support and guidance, directly and via qualified nonprofits, to low-capacity communities that need assistance developing projects. In particular, FEMA should provide guidance, including specialized technical assistance at the headquarters and regional levels, on how to overcome challenges faced by low-capacity communities seeking to access BRIC funds as well as suggestions on how FEMA can support those communities.
- Lastly, FEMA should provide transparency about its own capacity and whether additional staff or training are needed at headquarters or within regional offices to support the BRIC program.
- FEMA should increase funding to modernize and expand floodplain mapping and improve risk accuracy by incorporating future impacts. Likewise, the flood mapping process should be improved through increased transparency, use of the most effective technologies, and robust input and engagement with local governments throughout the duration of the process.
U.S. Department of Housing and Urban Development
Community Development Block Grant – Disaster Recovery Program
- HUD’s CDBG-DR program is a critical component of federal disaster recovery and resilience because it targets the unmet needs of low- and moderate-income communities. Because CDBG-DR funds can be used as a non-federal match to support recovery and rebuilding, this program also enables under-resourced communities to access federal resources that would otherwise be out of reach. However, because the CDBG-DR program has not been permanently authorized, a new Federal Register Notice must be issued by HUD each time these funds are appropriated. This ad hoc process has led to, and will continue to lead to, multi-year delays that are devastating for communities affected by disasters. Individuals affected by natural disasters often lack access to safe temporary housing while they await CDBG-DR funding and, due to funding eligibility policies that disincentivize self-made home repairs, might be forced to continue living in impaired, flood-prone housing for years after an event. By permanently authorizing the CDBG-DR program, Congress can recognize and support housing as infrastructure and ensure that HUD can get funds out the door quickly to the communities that have been hardest-hit by the COVID-19 pandemic and that face the greatest threats from disasters.
- The HUD CDBG-DR program should be permanently authorized with set timelines around release of funds. This is critical to shorten recovery times for communities affected by disasters, to synchronize timelines with other disaster recovery agencies (like FEMA), and to provide a stable source of recovery and resilience funding for low-capacity communities. Clear guidance governing coordination between FEMA and HUD around disaster recovery programs should be provided, particularly relating to the transition from FEMA recovery programs to HUD CDBG-DR.
- After Hurricane Florence, Congress appropriated funding to HUD to administer a Community Development Block Grant Mitigation Program (CDBG-MIT), which is supporting long-term projects that build resilience. Within CDBG-DR authorization, there should be a set-aside for mitigation.
- Permanent authorization legislation should also codify HUD practices of encouraging resilient rebuilding, including promoting nature-based solutions for addressing increasing flood risk and requiring that rebuilding avoids flood-prone areas where feasible or is built to address future flood risk.
- 65% of HUD’s state and local grantees are failing to meet their own goals. Grantees need technical assistance and coaching to build and execute high quality recovery and mitigation programs. HUD should create more funding for grantees to pursue training and technical assistance that specifically meets their needs and builds their internal capacity for future success in CDBG-DR and CDBG-MIT programs.
- Greater transparency is needed around HUD’s capacity to administer this program, namely whether additional staff are necessary and whether a centralized governance body, such as an Office of Resilience within HUD, is needed to ensure efficient program administration.
National Oceanic and Atmospheric Administration
- NOAA funds several restoration programs that contribute to community and landscape resilience, including the National Coastal Resilience Fund, administered by the National Fish and Wildlife Foundation. Greater funding is needed across NOAA’s coastal restoration programs in order to meet existing needs and enable shovel-worthy restoration projects to break ground. Not only will these projects increase resilience by protecting communities from storm surge, but they will also create jobs. Past analysis has shown that a $154 million investment supported 2,280 jobs, with an average of 15 jobs for every $1 million invested and up to 30 jobs on complex projects.2
U.S. Army Corps of Engineers
- The U.S. Army Corps of Engineers has a $98 billion backlog of authorized construction activities, including critical ecosystem restoration projects that promote resilience to flooding. Significant investment is needed to address the backlog of ecosystem restoration or flood risk reduction projects that aim to result in multiple benefits. USACE’s projects that incorporate nature-based approaches help to reduce flooding, create jobs, and provide additional social and environmental benefits for communities, and these types of approaches need greater consideration and funding from USACE.
U.S. Environmental Protection Agency
Clean Water State Revolving Fund
- States rely on the Clean Water State Revolving Fund to make investments in critical water infrastructure. Substantial investment in this program is necessary for states to make their water infrastructure resilient to increasing flood risk and other natural disasters.
- Natural and nature-based approaches are an essential component of resilient water infrastructure and should be incorporated into and encouraged by this program by setting aside a portion of SRF funds to the “green project reserve,” as has been done in previous appropriations legislation.
U.S. Department of Transportation
- Preparing our nation’s transportation assets for natural disasters is critical as it advances community resilience and creates jobs. Last Congress, several resilience provisions were included in the America’s Transportation Infrastructure Act of 2019 (S. 2302) and the Moving Forward Act (H.R. 2). We encourage Congress to build upon and expand these provisions.
- Authorization and funding are needed for a comprehensive competitive grant program that encourages states and communities to increase transportation assets’ resilience to natural disasters, including by deploying nature-based solutions for addressing risks to transportation systems and assets. By enabling planning, assessments, and crucial projects that reinforce and upgrade existing transportation assets in ways that account for growing risks, this program would ensure that critical transportation assets remain accessible during and after disasters.
- To avoid taxpayer dollars going toward rebuilding assets multiple times, require permanent work to repair or reconstruct repeatedly damaged Federal Highway Administration (FHWA) facilities using funds from the Emergency Relief Program (ER) to incorporate betterments or protective features that mitigate risk of recurring damage.
- FHWA should also consider creating a pre-disaster mitigation program that provides funding for long-term resilience upgrades of repeatedly flooded assets that utilize FHWA ER funds.
- DOT should consider opening up existing programs to incentivize investments in resilience, by ensuring that resilience projects are eligible within formula programs, by granting points to competitive program applicants for including resilience and nature-based solutions within their applications, and/or by providing other incentives.
- Resilience to natural disasters should be added as a fourth goal within the National Highway Performance Program.
Once again, thank you for your leadership in addressing the challenges our nation faces at this time. We are grateful for the opportunity to provide our input about the incorporation of resilience and adaptation priorities in an infrastructure package. We look forward to working together.
American Flood Coalition Action
Bipartisan Policy Center Action
Fair Share Housing Center of New Jersey
National Association of Clean Water Agencies
National Audubon Society
Rural Community Assistance Partnership (RCAP)
The Nature Conservancy
The Pew Charitable Trusts
Theodore Roosevelt Conservation Partnership