The National Environmental Policy Act (NEPA) and the National Historic Preservation Act (NHPA) requires construction projects utilizing federal dollars undergo reviews to evaluate their impact on the environment and on historical and archaeological sites. Currently, this will include homes being rebuilt in Houston using CDBG-DR funds from the federal government – even though the homes are merely replacing homes that had already been constructed, and thus pose little additional threat the environment or historic sites.
The NEPA and NHPA come at a significant cost, both in terms of dollars spent and valuable time utilized. Louisiana has estimated the cost of site-specific environmental reviews at $3,500 per home for its homeowner assistance program funded that was funded by CDBG-DR for the 2016 flooding in Baton Rouge.
With over 200,000 homes damaged in the City of Houston alone, the cost of site-specific environmental reviews would eat up $700 million of the city’s recovery funds, and the overall price tag for environmental reviews across the nation for Harvey, Irma, and Maria would range in the billions. The cost of those reviews could also increase as the unprecedented scale of housing damage throughout the country creates price competition for qualified environmental firms to perform the work. Every dollar we spend on unnecessary environmental and historic reviews is a dollar that is no longer available for rebuilding.
The City of Houston asks that Congress waive site-specific environmental and historic reviews for the rehabilitation or reconstruction of single-family homes outside the floodplain.
While the City agrees with the goals of NEPA and NHPA and believes the reviews necessary for large-scale infrastructure projects or new development, demanding these reviews for every structure when attempting to rebuild after a hurricane is simply going too far. Rehabilitation of single-family homes will not present any significant impacts on the environment, and there are no direct environmental risks associated with this course of action.
The White House has requested legislative authority in the disaster supplemental appropriations bill to streamline environmental review requirements for the rehabilitation of single-family homes outside of the floodplain. The City of Houston appreciates the administration’s request for legislative authority to streamline environmental reviews but believes this exemption should apply not only to CDBG funding but other federal sources of housing assistance for single-family home repairs (e.g. FEMA IA repair grants, PA-funded rapid repairs, or HMGP-funded elevations and retrofits). It is also important to exempt these homes from historic reviews as they pose the same potential for cost and delay on a site-specific basis. The requested language incorporates these two issues.
Sec.__. A federal agency action, including issuance of a permit, approval, or authorization for funding or reimbursement, associated with the rehabilitation or reconstruction of single family housing outside a special flood hazard area as designated by the Federal Emergency Management Association, when the need for such rehabilitation or reconstruction results from a major disaster declared [in 2017] pursuant to the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5121 et seq.), is exempt from the requirements of the National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.) and the National Historic Preservation Act (54 U.S.C. 300101 et seq.).