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Timing of Public Comment Period On State's Hazard Plan Raises Questions

In response to inquiries, the NJ Office of Emergency Management said that it would be postponing all interviews on the matter until after the comment period is over. “There have been some articles on this already written -- negative, positive, and neutral,” Goepfert wrote in an email. “We are trying to avoid those who wish to comment being influenced by what they are reading, or maybe refraining from commenting based on what they read or hear in the news.”

She did release a statement, though, reiterating that that state would carefully review all comments it receives and modify the plan after the fact, as it saw fit. “FEMA encourages states to constantly evaluate their plans, and liberally allows amendments,” she said.

Making Modifications

Indeed, even though the plan only undergoes a complete update every three years, it’s true that amendments can be added between now and the next time it’s officially revised in 2017. The section on plan maintenance clarifies that state officials will meet twice a year to make any modifications deemed necessary. Critics counter that they have no assurances that their comments will be considered at a future date. And they say that if state officials were sincere in their desire for input, they would have found a way to incorporate that feedback into the current plan before turning it in. While FEMA doesn’t mandate that states hold public comment periods prior to adoption of their Hazard Mitigation Plans, it does require that they consult with “interested parties” while they’re in the process of formulating their plans.

And according to plan documents posted on OEM’s website, state officials did seek input from close to 20 different groups, including government bodies like the Port Authority of New York and New Jersey, the Army Corps of Engineers, and the Delaware River Basin Commission. There were also members of academia, including the Richard Stockton College Coastal Research Center and the Rutgers Climate Institute. And a few outside groups like the New Jersey League of Municipalities and the New Jersey Association for Floodplain Management.

But the overwhelming majority of these interested parties were state organizations or state universities, said NJ Future. “They’re important stakeholders, but they have a formal role,” said Chris Sturm, the group’s Senior Policy Director. She thinks that if NJ Future had been consulted throughout this process, it would have brought to the table a perspective she said state officials didn’t appear to fully consider, including a detailed examination of land use and growth patterns to try to guide future development away from the riskiest areas.

Ask the Experts

Chuck Latini with the American Planning Association agrees. “I’ve got 1,200 members, and of those members, there’s a bunch who are leading experts in this stuff. And [if] you’re not involving them, then you’re not taking advantage of the resources the state has to offer,” he said.

It’s unclear why groups like NJ Future and the Planning Association -- which were knowledgeable and had volunteered to give input -- wouldn’t have been included. Equally elusive: what the state’s criteria were for deciding with whom it should consult. In her statement, Goepfert simply suggested that the state chose to rely primarily on groups that had been involved with the formation of Hazard Mitigation Plans in the past. “No organizations have been formally excluded from the planning process,” she said.

David Kutner -- who’s a Recovery Planning Manager at NJ Future -- points to nearby states that have taken vastly different approaches from New Jersey in updating their Hazard Mitigation Plans. Maryland, for example, held a series of workshops and open houses aimed at trying to get input from entities and organizations outside of state government, he said. “They really reached out to the community to engage them.”

Likewise, emergency management officials in New York State held a lengthy public comment period on their website before their plan was finalized. But here in New Jersey, Kutner said, “that kind of effort is really absent at a state level.”

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