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Flood of plain questions for GHA
By Julia Kamen
Contributor
Published October 28, 2009
In 1977, Executive Order 11988 of the federal government instructed the Department of Housing and Urban Development to “avoid direct or indirect support of floodplain development wherever there is a practicable alternative.”
Agencies such as Galveston Housing Authority, which are funded primarily by HUD, either comply with that directive or undergo a rigorous eight-step process to prove why they cannot.
Here is the process:
1) Identify whether the proposed location is in a 100-year floodplain.
2) Notify the public at the earliest possible time of a proposal to consider action in a floodplain and involve the public in the decision-making process. This must include notices published in local news media (including bi-lingual) and sent to federal, state, local, public agencies and organizations and any individuals known to be interested in the proposed action. The notice shall include name, proposed location and description of activity, and name and phone number of HUD official to contact for information. The public shall have time to comment.
3) Identify and evaluate alternatives to locating the proposed activity in a floodplain. These can include a) locations outside the floodplain, b) alternative methods of serving the same project objective or c) decision not to pursue any action.
4) Identify the direct and indirect impacts (including cost, hazard mitigation and safety) of locating in a floodplain.
5) Design to minimize potential adverse effects of locating within a floodplain, including early warning systems, emergency evacuation and relocation plan, and the elevation and satisfaction of increased code requirements for building in a floodplain.
6) Re-evaluate building plans in a floodplain, including all measures to minimize adverse effects, against the practicable alternatives identified in step 3.
7) If the re-evaluation results in a determination that there is no other practicable alternative than locating in a floodplain, then the agency must: publish to the public the reasons why, the list of alternatives considered and the mitigation measures to be taken to minimize the adverse impacts of locating in a floodplain. The public then will have time to comment before any action is taken.
8) Implementation must include all mitigating measures described in step 7.
The federal government has developed this process to ensure due diligence before spending taxpayer dollars to locate people in a floodplain, and rightly so.
Whether or not Galveston Housing Authority seeks funding from HUD, any agency, foundation or government entity considering funding the authority’s plans should be asking the same questions.
Based upon a one-page letter from the housing authority, Galveston City Council already has “earmarked” $25 million of the city’s recovery funds for the authority. GHA also will be at the table with its hand out when the next round of recovery funds becomes available.
Before the housing authority begins picking out paint colors and street trees, Galvestonians should demand thier city council ask it the same fundamental questions as the federal government, as to why it is building in a floodplain at all.
I urge islanders to write to their city council. We all deserve the answers.
Julia Kamen is a resident of Galveston.
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