Louisiana has a new draft of the 2017 Coastal Master Plan. The 2017 plan is focused on improving the ability of Louisiana’s coastal communities to face rising seas and increasing storms. The Master Plan proposes a combination of restoration projects, levees or other structural projects and a “nonstructural” (flood risk reduction) approaches to protect our coastal communities as we face continuing wetlands loss, rising seas, and increasing storms.
However, many hurricane seasons will come and go before the Master Plan’s restoration, levee and other structural projects are completed. In the meantime, the state must prioritize and fund flood risk reduction programs, such as elevating homes and flood-proofing buildings, in our state’s most at-risk communities.
Gulf Restoration Network, in coalition with the Bayou Interfaith Shared Community Organizing (BISCO), Coastal Communities Consulting, Gulf Restoration Network (GRN), Grand Bayou Village Tribe, Oxfam America, Terrebonne Readiness Assistance Coalition (TRAC), and Zion Travelers Cooperative Center with Tulane Environmental Law Clinic, are asking the state to ensure that the final Plan:
1. Prioritizes communities most at risk:
CPRA should flip prioritization to focus on those who are most at risk and low-income residents. Further, it should provide incentives for community-level approaches to elevation, flood-proofing, and relocation. The state should leverage its financial resources for developing community-wide approaches, encouraging neighbors to take action together to preserve the character and function of coastal neighborhoods as they take steps to improve collective resiliency. In particular, low-income residents living in areas with 14ft BFE or above and those who make their livelihood in the Gulf are the most at risk from coastal land loss. They need to know their options, as well as what the state is planning to do to help them beyond marking their communities as voluntary acquisition or a “resettlement zone”.
Our rural communities deserve to be prioritized for non-structural assistance and resources. Economic value of a residential community’s assets over time should not be based on population growth. Attachment C3-25: Storm Surge and Risk Assessment of the 2017 Draft Coastal Master Plan assumes that a home is more valuable over time if the surrounding population grows faster. This assumption about value is unsupported. CPRA also specifically looks at population change between 1950-2000. However, according to the U.S. Geological Survey Scientific Investigation about Land area change in coastal Louisiana from 1932 to 2010, low-lying coastal areas have been experiencing the impact of land loss since before 1950. The land loss is why people are moving away. This assumption about value over time based on population growth diminishes the prioritization and value of Louisiana’s low-lying residential communities that have been historically threatened by coastal erosion.
Low-income community members and those most at risk of flooding should be prioritized for nonstructural, rather than the current cost-benefit analysis equation being applied to nonstructural resource allocation.
2. Incorporates a community economic development approach:
The Draft Plan is missing a community economic development approach that is people-centered and benefits low and moderate income individuals and families through the creation of sustainable small business development programs and policies, as well as employment opportunities that pay living wages. Incentives need to be provided within the Coastal Master Plan to allow for local small businesses to benefit from contracting opportunities (i.e. accessible certification programs, preference to disadvantaged business enterprises, etc.).
3. Ensures that structural projects are accompanied by efforts to mitigate the impacts of those projects.
Commercial fishermen’s livelihoods and communities outside of those structural will be affected by large-scale structural projects proposed in the 2017 Master Plan revision. These structural projects must be accompanied by state efforts to mitigate negative impacts of these projects on local communities, such as flood risk reduction and the like. Our communities support a Multiple Lines of Defense approach to protecting our coast. However, we cannot ignore the impacts of these projects on our low-income residents and those who are most at risk.
4. Commit to ensuring that for every 80 cents allocated or spent on structural projects, 20 cents must be allocated or spent on a nonstructural project.
Structural and non-structural spending should be proportional throughout the planning, prioritizing, and implementation process. For nonstructural spending, the 2017 Draft Coastal Master Plan allocates $8.6 billion, or 17.2 percent of the overall $50billion budget. This is a 3.2 percent decrease from the 2012 Coastal Master Plan. The 2012 Coastal Master Plan - Distribution of Funding by Project Type, had set the amount at $10.2 billion, or 20.4 percent of the overall $50billion budget. The percentage of spending for nonstructural should be set at 20% of whatever amount gets allocated ($200 million per year).
In order to raise a portion of the funds needed for nonstructural projects, CPRA should pass a resolution dedicating a portion of annual offshore energy revenues coming to Louisiana under the Gulf of Mexico Energy Security Act (GOMESA) for funding nonstructural flood protection strategies and entrepreneurial support strategies.
5. Provides accurate, accessible and consistent information using trusted partners:
CPRA should circulate detailed, accessible and consistent information in a timeframe that allows for feedback and inclusion. The Authority must build partnerships with trusted community-based NGOs and tribal institutions, allowing them to provide case management services to low-income, rural, and other hard to reach communities to help residents and small business owners navigate the frameworks and implementation of nonstructural strategies. It is imperative that the Authority commits to not only listening to community questions, but works to provide well-reasoned and effective answers.
6. Treats public input as formal public comment and values citizens’ scientific knowledge.
The Draft Master Plan does not have proper community inclusion. Coastal residents and entrepreneurs comments and suggestions must be properly considered and incorporated in the Louisiana Coastal Master Plan, and subsequent annual plans. CPRA needs to formally respond the community how its suggestions were implemented during public meetings and formal comment periods, including if and why they weren’t incorporated.
The CPRA should develop a community engagement framework to inform coastal communities about their five-year plan prior to each revision. This framework needs to be written down and included in the plan so the Authority can be held accountable by the coastal communities it serves. The CPRA must present their project outline and impacts with ample time to receive feedback. This feedback should be publicly addressed by the CPRA at community forums where residents, fishermen and other coastal entrepreneurs can educate the state using their generational, cultural, and ecological knowledge; citizens’ science must be taken as seriously as other forms of scientific knowledge.
7. Gives equal weight to Community Stakeholder Group’s feedback in the planning process.
Community engagement and outreach must provide grounded solutions that anticipate and incorporate community needs based on the feedback provided by the Flood Risk and Resilience Stakeholder Group and the Community Focus Group. Both of these groups should follow the same feedback and comment process as all other stakeholder and CPRA Focus Groups that advise on the Coastal Master Plan.