April 4, 2013
The Honorable Henry Waxman & Sheldon Whitehouse
Co-Chairs, Bicameral Task Force on Climate Change
United States Congress
Washington, DC 20515
Dear Senator Whitehouse and Representative Waxman,
We write to commend you on the formation of the Bicameral Task Force and for reaching out so broadly in search of solutions to meaningfully address global climate change. We write under the same cover, and on behalf of our region. Three years ago, we came together as the Southeast Florida Regional Climate Change Compact, a collaboration of Palm Beach, Broward, Miami-Dade, and Monroe counties, together with many of our 109 municipalities and other stakeholders in southeast Florida, to establish a regional framework for reducing our emissions, increasing the resilience of our communities, and assuring the continued prosperity of our people. We write today in response to your broad call for comments on the federal role in combating climate change, particularly at the state and local scale. We believe our perspective—born of our experience of regional cooperation in an area particularly susceptible to the effects of climate change—has much to offer other regions of the country and to the federal approach to climate mitigation and adaptation.
The Compact developed out of a 2009 climate leadership conference convened by county commissioners in the four counties of southeast Florida, who realized that the counties shared common concerns and could accomplish more working together than they could apart. The Compact, a standing commitment to work together on climate mitigation and adaptation measures, has been extremely productive in its first three years of work, delivering a series of significant accomplishments:
- A unified sea level rise projection and a process through which regional scientific experts will review and update the projection, as necessary.
- The establishment of Adaptation Action Areas (AAAs) in state law. AAAs are an optional comprehensive plan designation for areas susceptible to sea level rise and coastal flooding which may be used to prioritize funding for adaptation planning and resilient infrastructure.
- The Southeast Florida Regional Climate Action Plan (RCAP), a five-year program of 110 action items to reduce greenhouse gas emissions and adapt to the effects of climate change.
- A three-year, $975,000 grant from the Kresge Foundation awarded in late 2012 to support implementation of the RCAP.
- A leadership role in the development of the Climate Resilience Element of Seven50, the Regional Prosperity Plan for the seven southernmost counties on the east coast of Florida, which is funded by a HUD Sustainable Communities grant.
- The Mayors’ Climate Action Pledge, an expression of support by municipalities for the Compact and RCAP. Solicitation of support for the Pledge is currently underway.
The work of the Compact is done largely at staff level, but with significant support from county leadership and extensive technical assistance provided by state and federal agency partners, including NOAA, USGS, and the Army Corps of Engineers. In working with these federal partners, it was abundantly clear to us that the regional scale of our collaboration enabled them to assist us in a highly effective way; our experience as a Compact is therefore quite relevant to federal policy. As a practical matter, our experience is a testament to the 2010 CEQ – Interagency Task Force Report to the President finding that “[a]daptation requires coordination across multiple sectors, geographical scales, and levels of government . . . Because impacts, vulnerability, and needs vary by region and locale, adaptation will be most effective when driven by local or regional risks and needs.”
If the federal role in climate change adaptation is to directly manage federal assets such as national parks and military bases, while providing scientific and technical assistance to state/local and private sector decision- makers, then how can this practically be accomplished across a nation of 3,000 counties and nearly 19,500 municipal governments? How can so many local governments access the considerable but diminishing scientific and technical resources of state and federal agencies? And how can we ever hope to align local, state, and federal policies and investments across so many “local or regional risks and needs” everywhere across the nation at once?
We believe that the incorporation of “regionalism” is the practical means to “think globally, but act locally.” There is ample evidence not only from south Florida, but also from other major regions around the country, that this approach holds much promise for federal policy. Some of our thoughts and suggestions are below:
- We are a single metropolitan area; it makes sense for us to act on this scale. So many of the issues we face—rising sea levels, water supply, transportation, and energy systems, to name just a few— cross jurisdictional boundaries and require close cooperation. And we are increasingly coming to recognize that global economic competition is among sub-state regions, rather than nations or states. Our region was the 49th largest economy on the planet in 2011, producing $260B in Gross Metropolitan Product. Regional cooperation should and must be fostered by the federal government.
- Meaningful cooperation across political boundaries is possible. By any measure, the governance of south Florida is highly complex, with several hundred units of government; whether and how the system might be improved is beyond the scope of the Compact. Our experience suggests that innovation and progress are possible within existing structures, provided that political support for the project and a strong core of professional staff members exist.
- Federal grant guidelines often encourage regional applications, but funding is often insufficient to implement programs on a regional scale.
- An exception to this tendency is the Seven50 Regional Prosperity Plan, funded by a HUD Sustainable Communities grant. The Sustainable Communities grant program, a collaboration of HUD, EPA, and USDOT, is an excellent example of the kind of multi-agency effort that should be supported by federal policymakers and deployed more frequently in support of local and regional partners.
- We recognize that new federal funding for state and local governments are highly unlikely given federal budget and political constraints, but we believe that existing funding streams could be better coordinated across agencies and levels of government by using regional frameworks such as the Compact. To this end, we recommend that the Task Force work directly with federal, state, and local agencies to identify barriers in law that preclude greater degrees of regional cooperation or create disincentives for doing so.
- Climate resilience should be built into project guidelines for federal infrastructure funding. At present, federal guidelines often focus narrowly on conventional measures.
- For example, FEMA mitigation dollars for hardening structures against hurricane-force winds—but do not encourage/permit funding for adaptive infrastructure improvements to roads, bridges, and drainage systems.
- Similarly, US Army Corps of Engineers projects are often designed around traditional “hard” engineering solutions, rather than “green” infrastructure which seeks to mimic natural systems and may prove more effective at meeting multiple goals (e.g. wildlife habitat in addition to flood projection).
- However, the Federal Highway Administration may serve as a model for adaptive infrastructure funding, as outlined in its September 23, 2012, guidance memo entitled “Eligibility of Activities To Adapt To Climate Change and Extreme Weather Events Under the Federal-Aid and Federal Lands Highway Program.
- Adaptation Action Areas should be recognized in federal law as a means of prioritizing funding for vulnerable areas and critical infrastructure.
- Infrastructure funding is a critical need. Many of the investments needed to successfully adapt to a changing climate or reduce greenhouse gas emissions would make sense even without those imperatives—in other words, they are “no regrets” strategies that reduce exposure to many types of risk. For example:
- A decentralized, smart energy grid composed of diverse energy sources is a hedge against rising fuel costs, shortages, and extreme weather damage.
- Investments in mass transit (not only new construction, but also operations and maintenance) relieve gridlock.
- Expected population growth alone requires investments in alternative water supply projects.
- Beach renourishment protects shorelines against erosion and tropical storm damage.
- Changes to the National Flood Insurance Program must be undertaken gradually to avoid disruption of the southeast Florida real estate market, which would threaten local governments’ financial prospects and our region’s ability to pay for our share of climate adaptation and mitigation measures.
We very much appreciate your continued leadership on this issue, and we look forward to working with you and your staff in any way that would be helpful to the purposes and objectives of the Task Force. The primary point of contact at the staff level for the Southeast Florida Regional Climate Change Compact is Jason Liechty, Environmental Projects Coordinator with Broward County; he can be reached at 954-519-0310 or firstname.lastname@example.org. Please do not hesitate to contact us if we can be of assistance to you.
Mayor Steven L. Abrams, Palm Beach County
Mayor Kristin Jacobs, Broward County
Mayor George Neugent, Monroe County
Mayor Woodrow L. Hay, City of Boynton Beach
Mayor John P. “Jack” Seiler, City of Fort Lauderdale
Mayor Matti Herrera Bower, City of Miami Beach
Mayor Craig Cates, City of Key West