FEMA Turning Blind Eye to NFIP’s Influence on Land Use (2)

Minot Airmen aid community affected by flood | US Air Force

FEMA recently published for public comment a draft Nationwide Programmatic Environmental Impact Statement (NPEIS) to evaluate the National Flood Insurance Program’s (NFIP) environmental and social impacts. In preparing the draft NPEIS, FEMA had a prime opportunity to assess the NFIP’s influence over land use in flood-prone communities and any corresponding environmental impacts, and to present potential modifications to the NFIP to mitigate any adverse impacts. Unfortunately, FEMA fell well short of the mark by failing to adequately evaluate the NFIP’s indirect effects on the human environment, such as whether aspects of the NFIP induce floodplain development. Further, the modifications proposed in the draft NPEIS are insufficient to improve the financial soundness of the NFIP, limit impacts to endangered species, and to protect people and property from increasing flood risks nationwide,

Instead, FEMA’s draft NPEIS reads more like an abdication of responsibility than a well-balanced and reasoned environmental impacts assessment. As discussed in “FEMA Turning Blind Eye to NFIP’s Influence on Land Use (Pt. 1),” FEMA narrowly interprets the concept of land use authority to find that it lacks the authority to direct development in floodplains and along coastlines. This tact excuses the agency from acting to mitigate any potentially adverse impacts associated with the program and from ensuring the NFIP is reducing current and future flood risk.  

These shortcomings are why NRDC, American Rivers, and Defenders of Wildlife have filed a comment letter (arnrdcdefenders_nfip_dnpeis_comments.pdf) challenging FEMA on its preparation of the draft NPEIS. The NFIP is a far reaching federal program that has implications for land use development, endangered species protections, and preparing for the impacts of climate change. In contrast, FEMA’s draft NPEIS leads…

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