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Letter to the Editor: HUD Moves To Protect Taxpayer Investments, One Foot Not Enough

November 3, 2016 Government, Opinion, Referendum No Comments

To the Editor:

Recent changes proposed for Federal floodplain protection reinforce that the garage proposal on the November ballot should be rejected. If the referendum is approved you can expect that the project will cost more than currently proposed to be consistent with the Federal requirements or offer less protection than deemed prudent by State and Federal experts resulting in greater risk of flooding and increased insurance costs.

Yesterday our resident nationally recognized emergency management expert, Bruce Lockwood, advised me that on Oct. 27th, one day after the Town meeting to send the garage question to referendum that the U.S. Department of Housing and Urban Development (HUD) proposed “Resilience Standard” to protect communities and taxpayer-funded investments from flooding. See press release and draft regulations: http://portal.hud.gov/hudportal/HUD?src=/press/press_releases_media_advisories/2016/HUDNo_16-165

The regulations when adopted would increase protection levels above the 100 year flood level.

There press release states “In the face of increased flooding risks and rising sea levels, the U.S Department of Housing and Urban Development (HUD) today proposed elevation standards for all HUD-supported properties. For the first time in nearly 40 years, HUD is proposing to establish higher elevation requirements for properties seeking HUD assistance or Federal Housing Admiration (FHA) mortgage insurance”.

Critical properties such as hospitals, nursing homes, and police/fire facilities would be elevated to three feet above the base flood elevation (also called the 100-year floodplain) or the 500-year floodplain, whichever is greater. Our highway garage and fuel storage for emergency vehicles are critical facilities.

HUD Secretary Julian Castro said “Our nation is faced with mounting and compelling evidence that future flooding events will be increasingly costly and frequent. If we are serious about protecting people and property from flooding, we have to begin to think differently than we did 40 years ago. Today we begin the process of aligning our regulations with the evidence to make sure taxpayer dollars are invested in the most responsible and resilient manner possible”.

We should expect that the federal and state standards enacted by FEMA and the State DEEP for floodplain management will be modified to confirm with this approach. In fact, the DEEP standards for sewage treatment plant expansions and/or upgrades now require the facilities be three feet above the 100-year flood elevation as I pointed out at the Town meeting on October 26th.

In the face of this recent activity the proposal to build a new highway garage in the floodplain should be reconsidered. Surely, the need to raise the facilities and provide flood mitigation for an additional two foot increase in the site will increase the project costs beyond the current estimated price and failure to do so will ultimately result in increased insurance costs. Expect the BOS to seek an additional funds for the project. Further site work will extend the construction schedule requiring alternative plans and expense for equipment storage.  In addition, should the state enact similar floodplain requirements prior to the proposed start of construction in 2018 it would require redesign of the project.

Dick Barlow
Canton 

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