ASFPM Submits Comments Supporting Proposed Changes by HUD and OMB
It has been a busy month for the ASFPM policy team with two sets of comments submitted in response to proposed changes by the Department of Housing and Urban Development (HUD) and the Office of Management and Budget (OMB).
On June 5, ASFPM submitted comments to HUD in support of a proposed rule that would revise the department’s regulations governing floodplain management and the protection of wetlands to implement the Federal Flood Risk Management Standard (FFRMS). The proposed change represents a major step forward in addressing future flood risk and ensuring the safety of HUD-assisted residents and federal investments.
In its comments, ASFPM commends HUD for showing leadership on this issue and offers detailed commentary and recommendations that we hope will be useful to help advance sound flood risk management and improve community, economic, and social resilience throughout the nation.
You can read ASFPM’s detailed comments here. HUD received a total of 122 comments during the public comment period. You can read them on Regulations.gov
In addition, ASFPM joined a sign-on letter from the Southern Environmental Law Center (SELC) supporting “HUD’s efforts to implement forward-thinking and climate-conscious standards that will prevent unwise development decisions and advance climate resiliency throughout the country and the South.”
The sign-on letter also provided a series of recommendations, including encouraging HUD to consider environmental justice holistically, actively engage impacted communities, promote nature-based solutions in regulations and guidance, prohibit the use of fill dirt to achieve elevation requirements, and more. In the conclusion, the letter noted “This rule is a critical step to increase flood resilience in our communities, particularly affordable housing, but HUD cannot stop here. For this rule to succeed, it must be accompanied by comprehensive guidance, maps and resources, technical assistance, and coordination at the program, departmental, and interagency levels.”
In addition to ASFPM, other organizations to participate in the sign-on letter submitted by SELC were Audubon South Carolina, Cahaba River Society, Charleston Waterkeeper, Enterprise Community Partners, Environmental Defense Fund, Harpeth Conservancy, Nature Forward, North Carolina Conservation Network, North Carolina League of Conservation Voters, Smart Growth America, South Carolina Coastal Conservation League, Virginia Conservation Network, and Wetlands Watch.
Guidelines and Discount Rates for Benefit-Cost Analysis of Federal Programs
ASFPM also submitted comments to the Office of Management and Budget (OMB) on proposed revisions to Circular A–94, which provides guidance on benefit-cost analysis and cost-effectiveness analysis of federal spending. Circular A–94 was last revised in 1992.
In the comments, ASFPM expressed strong support for the proposed discount rate change and noted that the association has advocated for a re-examination and change to the 7% discount rate for benefit-cost analysis for more than 20 years. As part of our comments, ASFPM also made five recommendations, including that OMB convene an economic task force to make recommendations for possible changes regarding economic planning and evaluation for flood-related projects as well as consider establishing a unified, flood-risk management related benefit-cost methodology for FEMA and USACE programs.
The public comment period is now closed, but the revised Circular can be accessed here. To view other comments submitted, go to Regulations.gov.
