[FoCHAT] From CHAT: Alert about Important HMGP Public Comments For Elevation Grants

Melanie Ehrlich mehrlich8 at yahoo.com
Wed Oct 31 16:26:50 PDT 2007


Dear Concerned Citizens,
  Thanks to Steve Donahue, our elevation PR person and Louisiana Land Trust expert, for alerting me to this important  public notice and invitation for public comments about a revision of FEMA's HMGP policy, which affects elevation grants.
  This is an alert to be ready to send in your comments by email by Nov. 4. This is important whether or not you are waiting for an elevation allowance and whether or not you have or are waiting for a grant because of its effect on S. Louisiana.
  DO NOT SEND IN COMMENTS YET BECAUSE I AM IN TOUCH WITH AN OFFICIAL WHO IS GATHERING INFORMATION TO GET THE RIGHT RESPONSE TO THIS COMPLICATED DOCUMENT. 
  ACCORDING TO THIS PERSON, THE POLICY IS DEFINITELY AN IMPROVEMENT BUT IT IS APPARENTLY NOT AS GOOD AS IT SHOULD BE FOR S. LOUISIANA'S POST-STORM BUILDING NEEDS. 
  THE NUMBER OF PEOPLE WHO RESPOND BASICALLY POSITIVELY BUT ASK FOR THE RIGHT REVISION OF THIS POLICY DOCUMENT CAN VERY MUCH INFLUENCE THE POLICY TO MAKE ELEVATION ALLOWANCES MORE REASONABLE. 
  THE OFFICIAL WILL SUGGEST THE MOST EFFECTIVE WORDING TO USE. 
  WE CAN ALL SEND THE SAME WORDING BUT IT MUST BE DONE BY SUNDAY, NOV. 4. 
  WE SHOULD GET EXACT INFORMATION TOMORROW OR FRIDAY.
   
  THE WEBSITE WITH THE DOCUMENT:
  http://www.fema.gov/plan/ehp/envdocuments/hmgp-pea.shtm
   
  In the meantime, here is an email explanation of the document from KC King, our CHAT elevation allowance expert.
  From KC:
  Folks,
  In regard to a FEMA Draft Programmatic Environmental Assessment Hazard Mitigation Grant Program Exception States of Louisiana and Mississippi October 2007, with a public comment period ending Nobember 4th, Melanie has asked me to: “make an outline of the parts of the doc that are RH relevant .”.  
   
  Highlights  The entire focus of the “exception” is relevant to road home option 1 awardees who have started or will have started 60 days (or less) prior to the exception being approved or the program agreements being finalized (whichever is later).  It also addresses non-Road Home grants for commercial structures and public works but, other than complicating the exception process, these are not of concern to home owners.
  For home owners who are elevating existing or rebuilt structures, FEMA concludes there is little risk to most of FEMA’s environmental and historic preservation objectives.  The exceptions are historically significant or potentially historically significant. Here FEMAs intent is negotiate programmatic agreement with the state(s).  By the way, potentially historically significant “could” mean anything older than 50 years. 
  If the exception is granted, home owners who have started elevation will be treated as if they had all the necessary approvals except the historical issues which we will know about later.  The paradox here is that those who have started may experience significantly less red tape than those who haven’t.  If you haven’t started, read this document for a preview of what you may be in for.  As we speak, the state is trying to forge generic boiler plate to cover all FEMAs concerns for those who haven’t started but their track record with FEMA has not been good.
  The index to the document (un-numbered, PDF page 2) provides a pretty good outline to the document if you want to delve into the details.  As a minimum you should read the roman numeraled section headers (I introduction, II Purpose and Need and  III Program Alternatives VII Conclusion
  Conclusions  Basically, the document takes 45 pages to say that homeowners should be granted exceptions and that some individual public works should be assessed.  I believe this is the correct and equitable approach.  I would go further to explicitly support alternative B4 which extends the exception to 60 days.
  There are still many battles to be fought, such as engineering feasibility and cost-benefit to make this a lean and equitable program.
   
  From me,
  Please continue your support of CHAT until all the eligible grantees get their fair grants, the Road Home-acquired properties are maintained properly, and their disposition is secured through plans that have meaningful community involvement (for New Orleans, that means the relevant one of the 13 planning districts).
  CHAT is not just about individuals getting their grants but the collective fairness of the program and its orientation toward the applicants' and the devastated districts' needs.
  Please:
  come for the first time or keep coming to our meetings if you are in the NO metropolitan area (every other week starting next week, meeting dates posted at http://chat.thinknola.com near the bottom of the page), 
  keep telling others to join FoCHAT at our web page (no dues, only infrequent emails), 
  and respond to our requests for emails or phone calls to state and federal officials and legislators.
   
  Best wishes and be ready for that email to FEMA in a day or two please. We'll give you the email address and suggest what you should write.
  Melanie
  Melanie Ehrlich
  Co-Chairman and Founder, Citizens' Road Home Action Team (CHAT)
   
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