Clock Is Ticking on Public Comment Period for Sandy Recovery Spending Plan

March 20th, 2013 by Peter Kasabach

Note: This post was originally published March 14, and has been updated below with a link to New Jersey Future’s comments on the plan.

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Late in the afternoon of Tuesday, March 12, the Christie administration released its proposed Community Development Block Grant Disaster Recovery Action Plan, which outlines how the state plans to utilize its $1.8 billion in federal Sandy-recovery funding. According to the official announcement, “This is the first phase of Community Development Block Grant funds provided to New Jersey by the U.S. Department of Housing and Urban Development. Additional CDBG recovery funds are expected in the coming months.”

The plan is posted on the state Department of Community Affairs website and as a downloadable PDF.

The release of the plan triggers a seven-day formal public comment period, which will extend until 5:00 PM on March 19. During this period, comments are being accepted via email  (SandyRecoverydcastatenjus)  .

The Christie administration will then submit the plan, including a summary of comments, to HUD for approval.

We at New Jersey Future are in the process of analyzing the plan and will be submitting formal comments, but one of our initial concerns is that the plan makes no provision for specific funds to help towns and counties plan for a more resilient and sustainable future. In light of the increasing frequency of severe weather events and rising sea level, we feel it is critical to provide funds to struggling municipalities to identify how they can keep their residents and businesses out of harm’s way and minimize the adverse economic impacts of major disasters like Sandy.

We urge all interested parties to study the plan, and to email any comments  (SandyRecoverydcastatenjus)   about how the funds are allocated. 

Update: Read New Jersey Future’s comments (PDF).

Posted in Cities and Towns, Community Design, Development and Redevelopment, Governor, Planning and Governance, Rebuilding A Resilient Shore, Redevelopment, Regional Planning

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2 Responses to “Clock Is Ticking on Public Comment Period for Sandy Recovery Spending Plan”

1. Peter Corless says:

   March 21, 2013 at 2:27 am

   I have similar issues to the ones that you raise, but you will note that this is the HUD Community Development Block Grant – Disaster Recovery Action Plan

   It is not a) an Army Corps of Engineers shoreline/littoral resilience plan, nor is it b) a FEMA Hazard Mitigation Grant Program (HMGP) plan.

   However, I feel as if it is vital to point out that a lot of dollars can be wasted in this program if each of the major programs — FEMA, HUD, USACE, and even the $800 Million in HHS monies — are all designed separately with no concept of a holistic community rebuilding and protection plan.

   In particular, the deficiency I find most striking in the use of the CDBG monies is similarly lacking in the New York State CDBG Action Plan — the lack of using the CDBG monies as part of a FEMA Hazard Mitigation Grant Program.

   Normally FEMA provides 75% of such funds, and requires states/local governments to provide the other 25%. But the CDBG monies can be APPLIED to such a HMGP!

   Only by having the HUD CDBG action plan done simultaneously in conjunction with a FEMA HMGP would you ever see that sort of funding synergy. If each of the programs are done separately, you are wasting an opportunity.

   Furthermore, why rebuild at all if, under the new FEMA base flood elevations, you are going to be required to rip out everything in a few years anyway or face dire flood insurance premiums?

   I’ve done a heck of a lot of number crunching here:

   • https://www.facebook.com/groups/RockawaysHurricaneSandy/doc/428085850605290/

   And I also wrote up my analysis of the NY State plan here:

   • https://www.facebook.com/groups/RockawaysHurricaneSandy/doc/446481025432439/

   Though there is no similar issue between the NYS/NYC division of spoils that NJ needs to worry about, the same issues of carts-and-horses (rehabilitation before hazard mitigation) applies to the NJ CDBG program.

   Call me at 650-906-3134 if you want to talk about this more.

2. Bill Wolfe says:

   March 27, 2013 at 11:02 am

   I closed my testimony on March 14 to the Assembly Homelands Security and Preparedness Committee with the same metaphor – the clock is ticking.

   I raised similar, issues, see:

   http://www.wolfenotes.com/2013/03/why-i-am-not-a-lobbyist/

   BTW< I note that NJ Future did NOT comment on DEP FEMA ABFE proposed rule, Readers interested in that and important DEP response document, see:

   http://www.nj.gov/dep/rules/adoptions/adopt_20130506a.pdf