The 30-day public comment period on the state’s new Hazard Mitigation Plan ends today – amid complaints by advocacy groups about the New Jersey Office of Emergency Management’s outreach efforts and mixed reviews for the plan itself.
The Hazard Mitigation Plan (HMP) includes an assessment of the risks New Jersey faces from a variety of natural and man-made disasters and lists steps being taken to minimize those risks. FEMA requires the state to update its plan every three years in order to receive hundreds of millions of federal dollars in pre-disaster and post-disaster assistance.
Now that planning advocates have reviewed the Christie administration’s HMP, it’s getting a mixed reaction. They applaud the plan’s acknowledgement of climate change but criticize it for not recommending a detailed plan of action to deal with it. Critics add that the plan spends too much time looking backward instead of looking ahead to a future likely to see significant change.
What’s more, several planning and environmental organizations had questioned the relevance of a comment period that didn’t even begin until six days after the state had already submitted its plan to FEMA. State officials responded that they had to turn in the plan to meet a federal deadline, and they pledged that any comments they received would be considered when drafting any future amendments to the plan.
Despite their frustrations, most groups said they still intended to contribute their ideas and suggestions for ways to make the state safer from future storms.
“We feel that it’s our duty as citizens of this state,” said Chuck Latini, president of the American Planning Association’s New Jersey chapter.
“New Jersey is going to be hit again by storms,” agreed Chris Sturm, senior policy director at New Jersey Future. “This need to become resilient is not a short-term problem. It’s a long-term issue that is requiring a shift I how we plan for disasters, and so our comments matter. If they’re not incorporated next month, they’re still important.”
As a senior policy analyst at the Natural Resources Defense Council, Rob Moore has reviewed Hazard Mitigation Plans from around the country. He said this new plan represents a “pretty positive step forward for the state of New Jersey.”
He applauded the inclusion of additional information about the impact of climate change that wasn’t included in previous plans, and the recognition that it could exacerbate existing risks.
“A lot of states don’t even do that,” Moore said. “From that perspective, New Jersey’s plan compares somewhat favorably to most other states.”
But he said the plan failed to take that acknowledgement of climate change to the next logical step by making concrete proposals for dealing with the problem. “What should we be doing differently now that we know that?” he asked. “I think that’s where New Jersey’s plan falls a little short.”
Moore noted that the plan largely relies on historical data to determine future risks of disasters.
“That’s the approach that almost all states take,” he said, “And it’s exactly the wrong approach right now. That approach only works if you know that risks are basically static, that past history is an indicator of the future. And, unfortunately, we no longer have that luxury because of climate change.”
Others were stronger in their criticism.
“There is no overall strategy for buyouts of vulnerable properties, updating codes, or even proper elevations. There is no strategy to reduce greenhouse gases or meet the goals of the president’s Climate Action Plan,” said New Jersey Sierra Club President Jeff Tittel, echoing concerns voiced by several environmentalists that the plan lacks specifics.
He also called for a state plan to pull back development from environmentally sensitive areas to allow more space for restoration of natural systems and dunes along the coast.
Bill Wolfe of the NJ Chapter of Public Employees for Environmental Responsibility said the plan failed to adequately address the growing hazards of river flooding inland and flooding along Barnegat Bay and Raritan Bay, adding that it only pays lip service to predictions about the future.
“The plan is studded with obligatory references to scientific findings on the effects of climate change,” he said, “but does not integrate that science into state planning or changes in building codes, project designs, regulations or plans to spend billions of federal aid dollars.”
Recognition of the threats of climate change, said New Jersey Future’s Chris Sturm, should be incorporated in all of the state’s funding decisions when it’s determining how to distribute mitigation and disaster recovery assistance. More specifically, she said a municipality’s vulnerability to sea-level rise should be a key factor in how much aid it gets.
Sturm called for more coordination and sharing of hazard information by various levels of government.
“If the state provides a template for this risk and vulnerability assessment, and if it trains the county planners, then they’ll all be doing it the same way” she explained. “And so we’ll have consistent risk assessments in each county, and we can stitch together a really comprehensive understanding of risk at the state level.”
“But if they’re all doing it their own way,” Sturm added, “without that kind of guidance and support, then we don’t get that consistent, comprehensive picture.”
Bob Kull is now co-chairman of the New Jersey Planning Association’s Hazard Mitigation and Recovery Planning Committee, but back in 2005 he helped draft the state’s original Hazard Mitigation Plan as a consultant for the Office of Emergency Management. He thinks the state’s latest plan is the most comprehensive to date, but he fears it may ultimately sit on a shelf and collect dust, never reaching those who might find it most helpful.
“Of all the people that should know about it, very few people (do),” he said. “Only a relatively few people in state government and their consultants were involved in its preparation. Drafts were never shared, to our knowledge, with leaders of other levels of government.”
Noting that most planning and zoning in New Jersey is done on the municipal level, he said local officials should have been more directly included in the formation of this plan.
“Both the product and the process are important if this effort is to make a difference,” he said. “It involves more than the emergency management community. It involves more than the first responders. It involves the people that shape land use and infrastructure going forward,” he said, adding that local planning boards, developers and the legal community were all stakeholders in the outcome. “All these individuals really should be involved in the process,” he said.