This is Climate Resilience Consulting’s response to the House Select Committee on the Climate Crisis’ Request for Information:
November 19, 2019
Email: ClimateCrisisRFI@mail.house.gov
RE: Climate Resilience Consulting’s Policy Recommendations to The House Select Committee on the Climate Crisis
Dear Congresswomen Castor and Members of the House Select Committee on the Climate Crisis,
Thank you for your important work. Please consider the following recommendations in response to your request for information, https://climatecrisis.house.gov/inforequest.
Overarching: The House Committee on the Climate Crisis should reframe your mission to be not only to “honor our responsibility to be good stewards of the planet for future generations” but also to “honor our responsibility to minimize the impact of the climate crisis on humanity.” Your current emphasis is about saving the planet. This recommended reframing focuses on saving Americans, the humans on the planet, and not only in future generations, but now.
1. What policies should Congress adopt to decarbonize the following sectors consistent with meeting or exceeding net-zero emissions by mid-century? Where possible, please provide analytical support that demonstrates that the recommended policies achieve the goal.
a. Transportation
b. Electric power. The Select Committee would like policy ideas across the electricity sector but requests specific comment on two areas:
i. If you recommend a Clean Energy Standard, how should it be designed?
ii. How can Congress expedite the permitting and siting of high-voltage interstate transmission lines to carry renewable energy to load centers.
c. Industry
d. Buildings
Sector-Specific Policies
For all policies, Congress should require that investments:
• Understand climate change risks – both hazards and vulnerabilities- faced by assets, activities and systems
• Address these risks through risk-reduction measures that account for climate change uncertainties
• Ensure assets deliver climate resilience benefits over and above addressing identified risks
• Do no harm to communities beyond asset boundaries to avoid perpetuating environmental injustice.
This will ensure that American’s tax dollars are spent on climate change resilience while mitigating greenhouse gas emissions. For further explanation, please see Climate Bonds Initiative, (September 2019) Climate Resilience Principles. https://www.climatebonds.net/adaptation-and-resilience
Transportation, Electric Power, Industry and Buildings Sector
In order to make informed infrastructure decisions (including for transportation, power, buildings and industry called out in your RFI), Congress should:
· Create a national infrastructure bank to further private investments in resilience
· Improve and align benefit-cost analysis across federal departments and agencies to account for full life-cycle and collateral benefits
· Develop metrics for rating the resilience of infrastructure including modernizing data analysis and production to include predicted climate scenarios wherever this is material, such as in federal floodplain maps
· Coordinate efforts of departments and agencies to increase efficiency in risk mitigation, resilience investments and disaster response
For further explanation, please see:100 Resilient Cities. (March 2018). Safer and Stronger Cities, Strategies for Advocating for Federal Resilience Policy.
2. What policies should Congress adopt to ensure that the United States is a leader in innovative manufacturing clean technologies; creating new, family-sustaining jobs in these sectors; and supporting workers during the decarbonization transition?
Congress should reframe the question to include climate change risk mitigation and adaptation: In policy creation, acknowledge that a just transition also relates to transitioning American workers away from jobs that are no longer feasible because it is too hot, too flooded or too devastated to continue with the work. Innovation in resilience, in addition to clean tech, will help US workers to thrive in a climate changed future.
Congress should develop institutional mechanisms related to health, education, housing, economic development and physical infrastructure to manage the climate-change driven economic losses that will have negative impacts on America’s families. Without targeted mechanisms these losses will increase racial and economic disparities.
3. What policies should Congress adopt to ensure that environmental justice is integral to any plan to decarbonize these sectors?
Congress should frame government procurement in the context of targeted universal strategies. “A targeted universal strategy is inclusive of the needs of both dominant and marginalized groups but pays particular attention the situation of the marginalized group. Targeted universalism rejects a blanket approach that is likely indifferent to the reality that different groups are situated differently relative to the institutions and resources of society.” (John Powell, Haas Institute) This will help stem the current tide of federal resources that go to relatively wealthy individuals and places and will begin to address historic lack of investment in modernizing infrastructure in poorer communities and the growing wealth gap perpetuated by disaster recovery (See, for instance: Howell, J., & Elliott, J. R. (2018). As Disaster Costs Rise, So Does Inequality. Socius. https://doi.org/10.1177/2378023118816795) This enabling environment relates to procurement rules, local job training programs, etc. One example, explored in response to question 11, is local hiring from disadvantaged groups for disaster recovery contracts.
Congress should emphasize resource-building in receiving communities as part of a strategy to make relocation from climate change hazards (e.g. river and coastal flooding, wildfire) the easiest, most dignified and most attractive option for property owners and renters to pursue. This relocation emphasis should be prioritized in fund allocations to FEMA, HUD and SBA for risk mitigation and disaster recovery.
Congress should put regulations in place that address increases in combined sewer overflows into household basements due to increased rate and volume of precipitation. Combined sewer overflows (also known as “water in basement”) are not Presidential declared disasters and result in repetitive loss. This household flooding devastates neighborhood and household income, savings and property values. It is caused in part by historic and current unjust zoning, and unequal infrastructure modernization.
Congress should change the current majority ratio of Housing and Urban Development’s funds on disaster recovery, increasing resources overall and especially for housing resilience for low and moderate income Americans.
Congress should acknowledge and halt the housing markets’ trend toward the next “big short,” as climate change causes rapid declines in river-, coastal- and forest-related property values with likely relatively more significant negative impacts on disadvantaged communities.
Congress should ensure that the Community Reinvestment Act (CRA) follows the recommendations in response to question one, above. (e.g. assess and address climate change risks, build climate change resilience, and do no harm to avoid perpetuating environmental injustice in each investment attributed to CRA compliance.)
Congress should create a Climate Community Reinvestment Act, that focuses on community resilience investments such as low and moderate income housing outside of flooding-, combined sewer overflow-, and wildfire-risk zones, cooling centers, natural infrastructure for heat and stormwater mitigation, etc.
Cross-Cutting Policies
4. Carbon Pricing:
a. What role should carbon pricing play in any national climate action plan to meet or exceed net zero by mid-century, while also minimizing impacts to low- and middle-income families, creating family-sustaining jobs, and advancing environmental justice? Where possible, please provide analytical support to show that the recommended policies achieve these goals.
b. How could sectoral-specific policies, outlined in questions 1-3, complement a carbon pricing program?
In a national climate action plan or otherwise, Congress should require that revenue from carbon pricing, such as tax revenue, should be applied to both furthering greenhouse gas emission reductions and creating climate resilience in America’s critical physical and social infrastructure.
Congress should reframe question 4a to say “What role should carbon pricing, climate change risk mitigation and climate change adaptation/resilience, play in…..”
5. Innovation:
a. Where should Congress focus an innovation agenda for climate solutions? Please identify specific areas for federal investment and, where possible, recommend the scale of investment needed to achieve results in research, development and deployment.
b. How can Congress incentivize more public-private partnerships and encourage more private investment in clean energy innovation?
In response to both questions 5a and 5b, Congress should focus an innovation agenda for climate solutions on resilience, including the following project types by sector:
· Water (Extreme Precipitation, Drought): Flood defense, wetland protection, stormwater management, rainwater harvesting, waste-water treatment relocation, strengthened water distribution systems, desalinization plants, etc.
· Buildings (Extreme Precipitation, Extreme Temperatures): Green roofs and walls, water retention gardens, porous pavements, etc.
· Forestry (Extreme Temperatures, Fire Weather): Wild brush clearing, species diversification, transmigration of species more capable of survival, afforestation and reforestation, mangrove conservation and replanting, etc.
· Energy (Hurricanes/Typhoons/Cyclones): Grid resilience, back-up generation and storage, etc.
· ICT (Extreme Precipitation, Extreme Temperatures, Hurricanes/Typhoons/Cyclones): Strengthened data distributions systems, climate monitoring and data collection that is applied to inform and build community resilience such as early warning systems, relocation or social networks, etc.
· Health (Extreme Temperatures): Treatment and monitoring for diseases that might increase due to climate change (e.g. vector-borne diseases), treatment of respiratory conditions from wildfires.
(reference Climate Bonds Initiative. (September 2019). Climate Resilience Principles. https://www.climatebonds.net/adaptation-and-resilience p. 10)
6. What policies should Congress adopt to reduce carbon pollution and other greenhouse gas emissions and maximize carbon storage in agriculture?
7. What policies should Congress adopt to help farmers, ranchers, and natural resource managers adapt to the impacts of climate change?
8. How should Congress update the laws governing management of federal lands, forests, and oceans to accelerate climate adaptation, reduce greenhouse gas emissions and maximize carbon storage?
9. What policies should Congress adopt to reduce emissions of non-CO2 greenhouse gases, including methane, nitrous oxide, and fluorinated gases?
Carbon Removal
10. How can Congress accelerate development and deployment of carbon removal technology to help achieve negative emissions?
In addition to carbon removal, Congress should establish a task force to examine geoengineering options and outcomes consisting of, at a minimum, geopolitical, science, engineering, innovation, social equity and ethics experts to address the existential threats of climate change and the relative benefits and disbenefits of geoengineering as part of climate change solutions.
Resilience and Adaptation
11. What policies should Congress adopt to help communities become more resilient in response to climate change? The Select Committee welcomes all ideas on resilience and adaptation but requests comments on three specific questions:
a. What adjustments to federal disaster policies should Congress consider to reduce the risks and costs of extreme weather and other effects of climate change that can no longer be avoided?
Congress should adopt policies that create an enabling environment for disaster recovery and response contractor hiring from local marginalized communities in order to accelerate economic recovery post-disaster and decrease the current trend of wealth redistribution to the wealthy post event. (See: Howell, J., & Elliott, J. R. (2018). As Disaster Costs Rise, So Does Inequality. Socius. https://doi.org/10.1177/2378023118816795) This enabling environment relates to procurement rules, local job training programs, etc.
As noted in response to question 3, above, given the extreme household-, community- and tax- revenue loss of repetitive loss and given growing climate hazards, Congress should prioritize relocation from climate change hazards (e.g. river and coastal flooding, wildfire) making every effort to ensure it is the easiest, most dignified and most attractive option for property owners and renters to pursue. This relocation emphasis should be prioritized in fund allocations to FEMA, HUD and SBA for risk mitigation and disaster recovery.
Also as noted above, Congress should change the current emphasis of Housing and Urban Development’s funds on disaster recovery, reorienting resources to housing resilience for low and moderate income Americans.
Congress should reform the National Flood Insurance Program (NFIP), following the expert recommendations in Peterson, Jeffrey. (2019). A New Coast: Strategies for Responding to Devastating Storms and Rising Seas. Island Press.
b. How can Congress better identify and reduce climate risks for front-line communities, including ensuring that low and moderate-income populations and communities that suffer from racial discrimination can effectively grapple with climate change?
Thank you for acknowledging racial inequities in the context of climate change impacts. As described in response to question 3, Congress should prioritize creating assets, including improving elements of the social safety net, in receiving communities that will welcome retreating front-line communities.
Anticipating community retreat and before shock events, Congress should support the systematic and just evaluation of property values, considering historic disinvestment in marginalized communities. Through various potential means, including the establishment of a national land bank for property buyouts, creating public amenities in bought-out neighborhoods and creating assets in receiving communities to improve all community members’ quality of life.
Congress, and all American leaders, should make it our mission to explicitly use the climate-crisis-driven migration of marginalized communities as an opportunity to explicitly remove racial discrimination and systemic injustice, so that current and future generations of Americans can thrive in The United States transformed into an equitable country. See Moser, Susanne et. al. (2017). The Kresge Foundation. Rising to the Challenge, Together: A Review and Critical Assessment of the State of the US Climate Adaptation Field. https://kresge.org/content/rising-challenge-together
b. What standards and codes should Congress consider for the built environment to ensure federally-supported buildings and infrastructure are built to withstand the current and projected effects of climate change?
Congress should:
Require the fast track modernization of flood plain maps to account for current and future hazards and vulnerabilities. Carefully scrutinize local government engagement in defining new floodplain boundaries, encouraging the transfer of local knowledge of stormwater, coastal and river flood mitigation efforts onto the maps, while prioritizing risk mitigation in land use and building decisions that inspires significant climate vulnerability reduction through retroactive, current and future land use changes.
For both federally supported and private projects, require the real estate sector to indicate the position of property within floodplains, once a land bank or other solution to compensate for plummeting home values in climate change hazard areas (see response to question 11) has been established,
As detailed in response to question one, for all policies, Congress should require that federally supported investments: understand and reduce climate change risks, create resilience benefits and do no harm to do no harm to communities beyond asset boundaries to avoid perpetuating environmental injustice.
This will ensure that American’s tax dollars are spent on climate resilience while mitigating greenhouse gas emissions. For further explanation, please see Climate Bonds Initiative. (September 2019). Climate Resilience Principles. https://www.climatebonds.net/adaptation-and-resilience
Climate Information Support
12. Our understanding and response to the climate crisis has relied on U.S. climate observations, monitoring and research, including regular assessment reports such as the National Climate Assessment. What policies should Congress adopt to maintain and expand these efforts in order to support solutions to the climate crisis and provide decisionmakers – and the American people - with the information they need? Where possible, recommend the scale of investment needed to achieve results.
The National Climate Assessment is great work. Congress should use nudge tactics to ensure every federal government appointee to read it, thus triggering staffers to read the Assessment too..
International
13. The climate crisis requires a global response. U.S. leadership is critical for successful global solutions. What policies should Congress adopt to support international action on the climate crisis?
Please see the above recommendation in question 10 regarding geoengineering.
With the greatest urgency and Statecraft resources, Congress should be an active participant driving solutions that save lives and improve livelihoods at every future UNFCCC Conference of the Parties as temperatures approach and likely crest the 1.5 degree Celsius target of the Paris Agreement.
Respectfully submitted by,
Joyce E. Coffee, President