Jul 6, 2021· Comment from Environmental Defense Fund, National Audubon Society, National Wildlife Federation, and The Nature Conservancy· OMB-2021-0005-0190
Attached you will find a cover letter (Attachment 1) and a letter on specific policy issues and recommendations with a supporting addendum (Attachment 2) in response to "Methods and Leading Practices for Advancing Equity and Support for Underserved Communities through Government, Docket (OMB-2021-0005), FR Document Number 2021-09109" from Environmental Defense Fund, National Audubon Society, National Wildlife Federation, and The Nature Conservancy. We thank you for the opportunity to provide input on such an important subject.
Jul 6, 2021· Comment from Environmental Defense Fund· OMB-2021-0005-0443
See attached file(s)
On behalf of our over 2.5 million members and supporters, Environmental Defense Fund (EDF) appreciates the opportunity to provide comments on the Office of Management and Budget's (OMB) Request for Information, Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government issued on May 5th, 2021. In the attached, we aim to provide OMB our understanding of how benefit-cost analysis (BCA) to evaluate flood protection infrastructure and pre-disaster mitigation proposals, as currently implemented by the Army Corps of Engineers (USACE) and the Federal Emergency Management Agency (FEMA), respectively, tends toward inequitable outcomes. We also hope to open a dialogue about potential solutions to make BCA more equitable.