ASFPM Submits Comments on USACE and HUD Proposals
Suggested changes in law, rules or procedures for Public Law 84-99
On Feb. 16, ASFPM submitted comments regarding a proposed rule to revise 33 CFR Part 203 (COE-2021-0008) Natural Disaster Procedures – Preparedness, Response, and Recovery Activities of the Corps of Engineers for implementation of P.L. 84-99, Section 5 of the Flood Control Act of 1941. In the comments, ASFPM noted that the association has long been concerned that the current and past implementation of P.L. 84-99 — the primary set of authorities of the U.S. Army Corps of Engineers to engage in natural disaster preparedness, response, and recovery — has often failed to actually reduce flood losses, and in many instances has exacerbated flooding costs and impacts by failing to fully consider alternative approaches to flood loss reduction that could be instituted in recovery efforts in the wake of flood disasters.
Download the letter regarding PL 84-99.
Recommendations for CDBG-DR Funds
On Feb. 21, ASFPM submitted comments in response to the Department of Housing and Urban Development (HUD) request for feedback on how to simplify, modernize, and more equitably distribute Community Development Block Grant Disaster Recovery (CDBG-DR) funds.
In the letter, ASFPM stressed our support for requirements that CDBG-DR projects adhere to the most stringent codes and standards enumerated for planning, development and construction as well as annual appropriation and pre-developed guidance so CDBG-DR assistance is not delayed. The letter took a more cautionary tone, however, with regards to using national level tools and datasets such as Climate and Economic Justice Screening Tool (CEJST) to implement President Biden’s Justice40 Initiative. “We strongly caution against viewing these tools and datasets as the final arbiter of which communities or neighborhoods might be economically disadvantaged, or dealing with environmental or social justice issues” and urged flexibility to allow more accurate state or local data to be considered, when available.