Agency Information Collection Activities: Proposed Collection; Comment Request; Property Acquisition and Relocation for Open Space

The Natural Resources Defense Council is providing comments specifically on the proposed Severe Risk Property Acquisition programs Pathway 2 option. As Pathway 2 is a major divergence from FEMAs current property acquisition practices and policy, with potentially significant consequences for hazard mitigation efforts, FEMA should not move forward with implementing Pathway 2 as an option. If FEMA persists in pursuing Pathway 2, the agency should provide for robust public input, including allowing for notice and comment rulemaking, before implementing such a radical change to FEMA policy and practice. FEMA should also present information justifying how Pathway 2 would be cost-effective, demonstrate any savings over alternative mitigation options, and propose limitations on it to ensure this would not be abused to spur coastal development.