Rutgers Sea Level Rise Maps Being Ignored by DEP
Best Available Science Shows Flaws in FEMA Advisory maps
Why Is DEP Ignoring Best Available Science?
The New Jersey Department of Environmental Protection is directing homeowners rebuilding after Sandy to consult with FEMA’s flood maps—which don’t account for sea-level rise—not the Rutgers map. But DEP spokesman Larry Hajna said the Rutgers tool could help residents affected by Sandy visualize “why it’s important to rebuild to the highest elevation possible.” ~~~ Wall Street Journal, 3/5/13
From day one, we have warned that the FEMA “Advisory Base Flood Elevation” (ABFE) maps do not consider the effects of projected sea level rise or climate change.
The FEMA ABFE maps also do not formally reflect the actual elevations we experienced during Sandy either, because they were developed prior to Sandy.
I believe that we were the first to break this story, (see this December 19, 2012 NJ PEER report:
[Note: this set of issues also involves maps based on data and statistics of past and current conditions, versus maps based on projected conditions. FEMA Climate Adaptation policy calls for maps to incorporate projected conditions, but historical FEMA practices were based on prior and current conditions. Projections are made more complex due to climate change, which involves sea level rise and the probability of more intense storms surge. Some argue that the historical data and statistical methods are not reliable, given climate change, e.g. the past will not be like the future, which violates a key assumption of the current statistical methods. I hope I don't botch that too badly - I am no statistician!]
But now, flood elevation maps released last week by Rutgers University prove our criticisms.
Those Rutgers maps (view interactive maps) now put the NJ DEP and Governor Christie is an extremely embarrassing spot, given the fact that the Gov. ordered DEP to adopt the FEMA ADVISORY ABFE maps by emergency regulation.
The FEMA maps and the DEP adoption of them have come under fire, mostly from economic and political interests that want to rebuild as fast and cheaply as possible and kill the FEMA maps completely, not those, like myself, who want to retain and strengthen the FEMA maps to discourage development in dangerous locations.
Some NJ legislators even called the DEP decision to adopt these FEMA maps “insane”. They have hidden this attack on science and sound policy behind defending poor and middle income constituents, who can’t afford to rebuild to costly FEMA requirements.
This debate will boil over tomorrow night in Long Branch, starting at 5:30 pm, in an “after the fact” pro forma public hearing on DEP’s Emergency Rule that adopted the FEMA ABFE maps.
Another negative news story is sure to stoke this debate.
Yesterday, the Wall Street Journal – no friend of climate change or limiting highly profitable shore development – reported on the failure of FEMA maps to reflect climate change and sea level rise (see the Wall Street Journal report):
SURF CITY, N.J.—While superstorm Sandy revealed the Northeast’s vulnerability, a new map by New Jersey scientists suggests how rising seas could make future storms even worse.
The map shows ocean waters surging more than a mile into communities along Raritan Bay, engulfing nearly all of New Jersey’s barrier islands and covering northern sections of the New Jersey Turnpike and land surrounding the Port Newark Container Terminal.
Such damage could occur under a scenario in which sea levels rise 6 feet—or a 3-foot rise in tandem with a powerful coastal storm, according to the map produced by Rutgers University researchers.
But the WSJ discloses that the NJ DEP is telling people to consult the flawed FEMA maps, not the Rutgers maps:
The New Jersey map stems from a $273,000 NOAA grant Rutgers received in 2009. The map has been tested by 60 coastal officials, and it was completed two weeks ago. Federal officials hope research institutions in other states undertake similar efforts.
“People are hungry for this data. The watershed moment was Hurricane Sandy,” said Doug Marcy, a hazards specialist at the NOAA Coastal Services Center in Charleston, S.C.
The New Jersey Department of Environmental Protection is directing homeowners rebuilding after Sandy to consult with FEMA’s flood maps—which don’t account for sea-level rise—not the Rutgers map. But DEP spokesman Larry Hajna said the Rutgers tool could help residents affected by Sandy visualize “why it’s important to rebuild to the highest elevation possible.”
DEP is handling this very poorly and simply not telling the truth.
In fact, the DEP Emergency Rule anticipates revisions to the FEMA ABFE maps – elevations are likely to go even higher when Sandy, Sea level rise, and climate change are considered.
DEP knows this. But they don’t want to tell people that elevations are going even higher and rebuild will be even more costly, because it will slow down the pace and scope of rebuilding, increase financial investment risks, and thereby undermine shore economic redevelopment.
Remember, Gov. Chrisitie has pledged to “Rebuild Now!” and he needs all those jobs and economic activity going into a fall relection campaign.
But enough of the politics, let’s get back to the wonk stuff.
Under the DEP emergency rule, any revised FEMA final maps automaticlly revise the NJ maps.
It is not our objective to discredit or block the FEMA maps, just the opposite. Let me explain what’s going on here and what went wrong.
Environmental regulations must be based on the “best avaiable science“. But science is always evolving, as new data and research emerges.
This dynamic reality forces government regulators to make judgements about where to draw the line, and when to go with the science you have as “best available science”.
This moving scientific target problem is made far more difficult when the “best available science” judgments involve computer models, complex environmental systems, and imprecise spatial (landscape) data – and used to support regulations with huge economic impacts.
Those situations require a careful, deliberate quality assurance process of “ground truthing” the maps and validating the models upon which they maps are based.
That’s why FEMA has an 18 month to 2 years process for finalizing “draft” ABFE maps -
But Gov. Christie and his DEP Commissioner, lacking any understanding of the science or mapping issues, short circuited this process of refining the FEMA maps by adopting them as final via DEP Emergency Regulation.
This move showed poor judgement and violates the FEMA process.
It even precludes the less rigorous traditional administrative public notice and comment regulatory process, which could have served to corrrect maps flaws.
Now, because flaws are being exposed and more recent maps are emerging, FEMA opponents – many who want to Rebuild Now! and reduce costs – are using BOTH the original flaws in FEMA maps and this newer science to politically attack and take down the entire enterprise.
We’ve seen this before.
DEP Commissioner Campbell was warned multiple times by experts NOT to use DEP GIS based maps for regulatory purposes before he rolled out his “Big Map” fiasco.
But Campbell was trying to develop a GIS map based framework that strengthened DEP regulations and discouraged developent in environmentally sensitive or hazardous locations.
We can’t same the same thing about the Christie/Martin motivations and objectives, which were to reduce “regulatory uncertainty” and accelerate rebuilding in exactly those locations and promote his own political interests.
This is the result of the Governor’s ideological opposition to regulation and his deep misunderstanding of how the economy works – Republicans always blame lack of private investment on “regulatory uncertainty” and therefore move to remove “regulatory barriers” and “job killing red tape”.
We’ll keep you posted. See you tomorrow night in Long Brancch.