[FoCHAT] CHAT Alert!: By Nov. 6-- chance to get reform of FEMA elevation allowances for Lousiana homeowners

Sat Nov 3 08:49:28 PDT 2007

To the Press and Citizens Concerned About The Rebuilding Storm/Flood-Devastated Parts of Louisiana,

  ALERT!: SEND PUBLIC COMMENTS about 

  http://www.fema.gov/plan/ehp/envdocuments/hmgp-pea.shtm

  BY NOV. 6 to FEMA to ask the agency to remove ridiculous red tape from house elevation grants for those with 2005 hurricane damage and to make them available for all houses in areas at risk, not just those that already have or had 2005 hurricane/flood damage. 

  We hope that citizens from all parts of our country will spread this message far and wide this weekend or Monday because FEMA does count responses and can be heavily influenced by them. 

  We hope that the media will publicize this by Nov. 5.

  More information at CHAT's website

  http://chat.thinknola.com

  There you will find a PDF of the suggested letter below and a more detailed PDF from a State official about the public's chance to make comments on a proposed FEMA policy for house elevation allowances. 

  FEMA created confusion (what's new?) about the deadline for comments, with one notice stating Nov. 4 and another Nov. 6. It is probably Nov. 6.  

  Please send your email to: FEMA-pea-comments at dhs.gov and also forward a copy of your email to chatlra at yahoo.com so that we can report to our State official liason about how many people have sent public comments supporting the position described below.

  In summary, either copy and paste the letter below as is, change it however you like, or get more information and PDFs from our website http://chat.thinknola.com

  Sorry that I am sending this information so late but FEMA gave very little notice (isn't that evidence of how much your public comments can count?) and I just received the excellent critique of FEMA's proposed policy change from my State liason.

  Email:   FEMA-pea-comments at dhs.gov  
  Fax:        504-762-2871
Phone:    504-762-2425 (during business hours)
Mail:       FEMA
              Environmental/Historic Preservation Office
              1 Seine Court
              New Orleans, LA  70114

  To Whom It May Concern:

  Thank you for publishing a conceptual framework for making changes to the Hazard Mitigation Grant Program.  This change is very important to the homeowners of Louisiana who have been seeking assistance to mitigate their homes in order to prevent future damages, but who have been stalled for far too long in their process of rebuilding.  FEMA has stepped up to introduce flexibility to a federal program at a critical moment, and the agency should be applauded for their efforts.

  As much as possible, the HMGP program should also be changed to increase the pace of the program’s assistance getting into the hands of homeowners.

  However, serious concerns that need to be addressed in an improved document are detailed below.

  Comments on Draft Programmatic Assessment of Hazard Mitigation Grant Program Exception for States of Louisiana & Mississippi

  Page 3:  This language needs to include “Mitigation Pilot Reconstruction,” as this term appears elsewhere in document and addresses a specific action approved for the Katrina and Rita disaster declarations. Additionally, there needs to be an inclusion of undamaged structures in this PEA alternative, which is consistent with the intention of the HMGP (the point of the program is to reduce risk, and is not related to whether a facility is damaged or not).

  Page 3: What level and type of documentation, permits, inspections, licenses, etc. will be deemed acceptable when dealing with “Work in Progress or already completed” projects?  What would be the minimum requirement for documentation for “Duplication of Benefits?  The answers to these questions could either create a manageable and efficient program, or could result in months or years of delay in implementing what is proposed as part of the PEA.

  Page 3:  The PEA states that “Projects must obtain and comply with all applicable permits (e.g. National Pollution Discharge Elimination System [NPDES] permits, CWA Section 404 General or Individual Permits, Storm water Pollution Prevention Plans [SWPPP], Incidental Take permits [ESA Section 10(a)(1)(b)], building permits for construction in the floodplain, coastal use permits, etc.). Projects that did not obtain applicable permits and properly implement permit conditions would not be eligible for HMGP funding.”  FEMA needs to make sure this requirement is provided with sufficient guidance regarding what is and is not considered acceptable.

  Page 3:  Alternative B-1: (1) Would it matter what the funding source was used to perform project activity I.E. Demolition and it’s affect on eligibility? (Say insurance money was used vs. a demolition performed by FEMA and US ACE?); and (2) Why does the PEA exclude non-damaged structures, which are equally eligible under the HMGP and whose risk is equally as important to mitigate?  

  Page 3: The timeline for the sunset period should be removed.  If it is not removed, it should be extended to two years. The reasons are as follows: Under the State of Louisiana’s State Hazard Mitigation Plan (approved by FEMA), as well as eligibility criteria for DR-1697 Hurricane Rita, a non-damaged homeowner could mitigate their home with FEMA HMGP funds. Since the purpose of the HMGP is to address risk regardless of damages, and the fact that we are more than two years after the declared event has already been determined a justifiable reason to provide program exemptions (since it is not reasonable to expect people or sub-grantees to delay addressing their risk for such an extended period), why are non-damaged homes and structures not addressed within this PEA?  This is inconsistent with the HMGP program’s intent, as well as the State’s plans and priorities for mitigation funding.

  Page 13:  Section V. B. 1. Securing a water quality certification for each individual project from LA DEQ Water Quality is an unreasonable request.

  Page 13: Section V.  B. 1 As LA DEQ evaluates project activities, relative to construction activities and environmental considerations, programmatic exemptions should be submitted by LA DEQ for those actions posing negligible effects.

  Page 19:  FEMA has already provided a Programmatic 8–step process that applies to all storm-impacted parishes, so we believe that same process should be utilized here.

  Page 33:  The 60-day deadline is unnecessary and unreasonable.  It should be removed. If not removed, it should be extended to two years (24 months) after the release of these program exemptions.

  YOUR NAME AND ADDRESS HERE

  - - - - - - -

  Lastly, CHAT is still very concerned about the lack of promised reforms of the Road Home Program. 

  We intend to further publicize and do more about Road Home problems and promised, but not forthcoming, solutions. 

  You may go to our website 

  http://chat.thinknola.com

   to see also newly uploaded documents as described below.

  Dispute Resolution and Appeals  There is much to be fixed with the Road Home Dispute Resolution and Appeals processes. Here are the latest documents available to CHAT from the Office of Community Development and LRA. They have not yet instituted important reforms promised months ago.

   Road Home Dispute Resolution and Appeals July Policy Document 

   Road Home Dispute Resolution and Appeals Nov. 1 Memo 

  Best wishes,

  Melanie Ehrlich
  Founder and Co-Chairman, Citizens' Road Home Action Team (CHAT)

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