NJ Department of Community Affairs
101 South Broad Street
Post Office Box 800Trenton, NJ 08625-0800
March 5, 2014
SUBMITTED VIA E-MAIL
RE: New Jersey Action Plan Amendment Number 7, Substantial Amendment for the Second Allocation of CDBG-DR Funds
Dear Ms. Gallagher:
The Christie Administration announced a proposed Community Development Block Grant Disaster Recovery Action Plan to use and distribute $1,463,000,000 in federal funding for Superstorm Sandy disaster recovery through the Department of Community Affairs (DCA). This allocation represents the second phase of the initial $5,400,000,000 provided by the U.S. Department of Housing and Urban Development under the Disaster Relief Appropriations Act of 2013 (Public Law 113-2, approved January 29, 2013).
Clean Ocean Action (COA) is a broad-based coalition of 135 conservation, environmental, fishing, boating, diving, student, surfing, women’s, business, service, and community groups, with a mission to improve the degraded water quality of the marine waters off the New Jersey/New York coast.
COA appreciates this opportunity to provide comments on the Action Plan Amendment Number 7, Substantial Amendment for the Second Allocation of CDBG-DR Funds (“Action Plan”). With this round of Sandy recovery funding, now is the time to think beyond fixing the damage done and look forward toward increasing resiliency. As a clean ocean is critical to New Jersey’s coastal economies, including tourism and commercial fishing, COA especially urges the State to implement projects that protect and improve water quality in the face of impacts from ongoing and predicted climate change and sea level rise.
COA presents the following comments to the Action Plan:
Sea Level Rise and Climate Change
As we rebuild our coastal communities, we have an unprecedented opportunity to benefit from lessons learned and implement changes to address future challenges. Importantly, as directed by HUD, the state must incorporate projections on sea level rise and climate change in its project planning process, to ensure that monies are invested in long-term community resiliency and conservation programs built to evolve with changing conditions and socioeconomic needs. We applaud the State’s intent to use the NOAA Sea Level Rise predictive tool in developing the infrastructure Flood Hazard Risk Reduction Program. However, all projects – infrastructure, housing, and business related – must be planned for the inevitability of sea level rise and increases in extreme weather events. Furthermore, mention of climate change is noticeably absent from the Action Plan; nowhere in its 100 pages is the phrase even mentioned, despite the fact that HUD has directed grantees to employ a risk analysis for infrastructures that “must consider a broad range of information and best available data, including forward-looking analyses of risks to infrastructure sectors from climate change.” COA urges the State to include information in the Action Plan on how future climate change risks will be incorporated into its infrastructure projects.
Blue Acres Buyout Program
COA applauds the State’s continued funding of the Blue Acres buyout program as a way of providing a natural storm buffer via restoration of coastal areas to their natural states. Although the value of coastal property is often tied to its development, a State assessment of the value of New Jersey’s natural capital estimated that wetlands contribute $10.6 billion annually to our economy solely for their role in storm surge and flood protection, water filtering and supply, and waste treatment. The report contains numerous other examples of the benefits healthy coastal ecosystems provide. The ability of intact natural landscapes to absorb wind, waves, and water can prevent untold damages to land and livelihood, while enhancing nearby property values. Because of these numerous benefits, COA urges the State to expand the Blue Acres buyout program and continue to appropriate funding to the program in the Action Plan amendment for the third round of Sandy recovery funding and beyond. Although this program offers promising benefits to flood-prone communities and the environment, the Action Plan does not provide discrete information on how properties are prioritized and ultimately selected for buyouts. For example, the Action Plan mentions that the State has approved the purchase of 272 properties in Sayreville and South River, but does not indicate why or how these areas were selected. Transparency is critical to ensuring that residents of flood-prone areas are made aware of their options under the Blue Acres buyout program.
Infrastructure problems plagued a significant number of New Jerseyans during and after Sandy: 94 wastewater treatment facilities located in all 21 counties experienced failures or disruptions at some point during the storm and over a third of residents were without power for six or more days after the storm. Not only has New Jersey’s water infrastructure been subject to extreme storms, it has also been subject to inadequate planning and financing to protect, maintain, and upgrade these systems for decades. The recent storms have brought the attention to the vulnerabilities and the need to support and improve these drinking, stormwater and wastewater systems. The plan’s prioritization of crucial services such as water and wastewater plants is to be commended; however, rebuilding also provides an opportunity to address chronic development-related problems such as inadequate stormwater management and substandard sewage infrastructure and treatment. Improving the status and resiliency of our water infrastructure (drinking, wastewater and storm water) is critical for water conservation, protecting public health, reducing flooding, improving water quality, and preventing future system failures – which in turn improves our quality of life and vital tourism industry. Funds applied to upgrading damaged and aging wastewater treatment and power distribution systems is money well spent, and will provide benefits for all residents for years to come.
Given the limited amount of money going to infrastructure in this round of recovery funding, it is extremely important that the State prioritizes spending of public funds in ways that maximize community and economic resiliency, reduce impervious surfaces to allow water to naturally infiltrate into the ground and reduce pollution, support and promote natural-resource dependent economies, and mandate green infrastructure and sustainable land use planning. The Action Plan states that in “designing resilient coastal risk reduction projects, the State will assess the feasibility, efficacy, and cost-effectiveness of incorporating nature-based infrastructure, including living shorelines, use of wetlands, dunes, and beach nourishment to reduce surge and flood volume.” As referenced above, New Jersey’s assessment of natural capital has clearly demonstrated that natural systems intrinsically provide great value. It makes economic sense to use nature-based solutions in building long-term resiliency. In addition, US Strong, an initiative focused on building support for extreme weather relief and protection, has cited studies that show every one dollar spent in disaster prevention can avert up to nine dollars in clean-up and recovery costs. We should focus on funding innovative and forward looking measures to protect our coastal communities, including an increased use of natural storm buffers, such as dunes and wetlands, over solely hard structural barriers.
The Action Plan mentions extensive research that is on-going within State agencies and at universities. This research should be focused on assessing the environmental and socioeconomic benefits of investing in long-term community resiliency and conservation programs built to evolve with climate changes and socioeconomic needs. Research should also be made available to the public, and the State’s decision-making process for prioritizing projects and areas should be transparent and based on the best available data.
Comparison to New York Action Plan
Both New Jersey and New York suffered enormous losses due to Superstorm Sandy. New Jersey’s second round funding allocation of $1.463 billion represents about 7.6% of the total $19.283 billion in unmet need estimated by the state. In comparison, New York received more funding this round than New Jersey ($1.595 billion), which represents approximately 10.2% of their total unmet need ($15.710 billion). Importantly, the New York Action Plan breaks out its assessment of unmet needs into four categories: housing, business, and in three described in the New Jersey Action Plan, and a fourth category called resilience. The New York Action Plan makes strong references to the importance of considering climate change impacts recovery projects and in planning for the future: “climate change” is mentioned 11 times in the document, whereas the New Jersey Action Plan does not even mention the phrase once.
With respect to increasing resiliency in the face of climate change, New York has taken proactive planning steps and created the New York City Special Initiative on Resiliency and Rebuilding (SIRR), which is “responsible for developing a plan to make New York City more resilient to the impacts of climate change, has also undertaken a massive effort to increase the resiliency of the hardest hit areas.” The SIRR met with elected officials, organizations, and the public, conducted extensive research and predictive modeling on climate change impacts to the city, and released an over 400-page report in June 2013 that contains over 250 detailed infrastructure and coastal community resiliency building initiatives. New Jersey should use this initiative as a model for a collaborative, forward thinking planning process and undertake similar assessments of climate related risks to our coastal communities.
Furthermore, New York has recognized the importance of regional collaboration in recovery and planning efforts, as climate change impacts know no political boundaries. New York City representatives have convened meetings with city representatives from both Connecticut and New Jersey. The Joint Climate Resilience Committee, formed with partner cities in New Jersey including Jersey City and Hoboken, was formulated to share key information resources and best practices within the region and integrate climate resilience within the consortium’s activities, was not even mentioned in the New Jersey Action Plan. These regional initiatives should be publicized and continued, to show New Jersey citizens that our state officials are thinking holistically about recovery and integrating programs with our neighboring states.
By making transparent, effective long-term planning decisions that will benefit all New Jerseyans, we can help ensure that this funding is used efficiently and we are prepared for the next storm. We are interested in working with the State in implementing prospective programs that will improve resiliency and coastal water quality, and look forward to opportunities to meet with you to work toward these goals.