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Public Needs to Question Building in a Floodplain!
by Julia Kamen
01 November 2009

In 1977, Executive Order 11988 of the U.S. Federal Government instructed HUD to "avoid direct or indirect support of floodplain development wherever there is a practicable alternative". Agencies such as GHA, which are funded primarily by HUD, either comply with that directive or undergo a rigorous 8 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 time possible 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 medium (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 reevaluation 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 will then 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 insure due diligence before spending taxpayer dollars to locate people in a floodplain, and rightly so.

Whether GHA seeks funding from HUD, or elsewhere, ANY agency considering funding GHA’s plans should ask the same questions.

Based upon a one page letter from GHA, our city council has already “earmarked” $25 million dollars of Galveston’s recovery funds for GHA. GHA will also be at the table with their hand out when the next round of recovery funds become available.

Before GHA begins picking out paint colors and street trees, we should demand our city council ask GHA these same fundamental questions as the Federal Government, as to why we are building in a floodplain at all.

Write to city council. We all deserve the answers. 

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