Letter to Deanne Criswell, Administrator of the Federal Emergency Management Agency - Fighting Against Harmful Algal Blooms

Letter

Dear Administrator Criswell,

Harmful algal blooms (HABs) have been reported in every state, posing dangers to public health, local economies, and the environment. Presently, affected communities cannot use Hazard Mitigation Assistance (HMA) funding to mitigate the impact of HABs. State and local governments should have the option to use these funds to mitigate the threats posed to their communities by HABs and other water quality and ecological issues. Therefore, we request that the Federal Emergency Management Agency (FEMA) identify HAB mitigation actions as an eligible activity for HMA.

HABs are a growing problem that present disastrous risks to health, business, and ecosystems. HABs occur when algae colonies grow in excess and create dangerous toxins. They can cause serious health problems and, in some rare instances, death. Researchers estimate that preventing or treating these blooms has cost over $1 billion over the past decade, not including the steep loss of revenue and damage to communities across the Nation.

The 2017--2019 K. brevis bloom in Florida, known as the red tide, caused over $1 billion in losses as well as over $100 million in lost tax revenue. Additionally, several groups of toxic cyanobacteria, known as blue-green algae, have been detected in Florida's waters. The groups Microcystis, Anabaena and Cylindrospermopsis and their associated toxins -- microcystins, anatoxin-a and cylindrospermopsin, respectively -- all occur in Florida freshwater systems, including those used for drinking water. Persistent cyanobacteria blooms have affected many of Florida's aquatic systems, including Lake Okeechobee; the Harris Chain of Lakes (Apopka, Eustis, Griffin and Harris); and the St. Johns, St. Lucie and Caloosahatchee rivers and estuaries. Persistent HABs occurring in the Indian River Lagoon have contributed to a substantial decline in seagrass, a critical food source for manatees, which has led to record number of manatee deaths. The Working Group on Marine Mammal Unusual Mortality Events and the U.S. Fish and Wildlife Service have declared the over 1,600 manatee deaths since December 2020 an Unusual Mortality Event (UME).

Mitigation can be a powerful tool to fight HABs. However, the present HMA guidance from 2015 deems activities that address "water quality infrastructure" or "ecological or agricultural issues" as ineligible. The current guidance pre-dates the Building Resilient Infrastructure and Communities (BRIC) and thus does not reflect the priorities of the BRIC program. The Biden Administration has strengthened the BRIC program, investing over $1 billion to help communities adapt to climate change and natural hazards. BRIC explicitly prioritizes projects that "reduce risk to Community Lifelines and infrastructure," which includes water sources and nature-based solutions. For example, projects selected for further consideration for FY2020 BRIC awards include those that improve habitats and enhance ecology. HAB mitigation would address similar objectives. While some funding exists for studying and preventing HABs, these sources do not sufficiently address the scope of the problem or provide adequate resources for managing HABs and reducing their damage. HMA funds are meant to expand beyond current efforts, rather than duplicate existing funding streams.

FEMA is presently updating HMA guidance to better align with existing policies, including those expressed in BRIC program. We request that the guidance is updated to include mitigation activities related to HABs as eligible activities under all HMA programs, including BRIC, Hazard Mitigation Grant Program (HMGP), and the Safeguarding Tomorrow through Ongoing Risk Mitigation (STORM) Act state revolving loan program. Communities should have the option to mitigate HABs, instead of waiting to recover from their devastating impacts, and would benefit from Federal mitigation funds.

Thank you for your time and attention to this critical issue.