The debate surrounding flood “resilience” has been filled with talk of rising seas, climate change and imminent coastal exodus — lures meant to distract us from rigorous thought.
On the surface, we all agree with the need for communities to be resilient to flooding and other threats. It’s like motherhood and apple pie; we all want it.
{mosads}But how much can we afford and what kinds of resilience would achieve the best outcomes for the sacrifice? What does resilience really mean in the flood policy context? Congress doesn’t appear to know.
Last year, legislation directed the president to define the term by rulemaking. If he wants help clarifying resilience, he’d get it from legions of rent-seekers, academics and agenda advocates. Like “sustainability,” resilience is in the eye of the beholder. It can be whatever your special interest needs it to be.
We’re not sure that hitching our wagon to the resilience star has merit, but there is a good way to give operational meaning to the idea or to otherwise respond rationally to flood risk. Economist Thomas Sowell has taught us a profound insight: “There are no solutions, there are only trade-offs; and you try to get the best trade-off you can get, that’s all you can hope for.” We cannot achieve a perfect outcome. Various pathways may contribute to our shared objective for increased resilience to weather-related risks. But the desirability of these alternatives must be understood in terms of the trade-offs among their benefits and costs. We should consider these trade-offs and choose the best one.
Sowell recommends that we ask three questions when evaluating public policies aimed at important social objectives like flood protection.
1. Compared to what? Policymakers should ask why a resilience measure such as removing a community from a flood plain, for example, is better compared to other alternatives such as elevating houses or building a flood protection system?
2. At what cost? Alternatives and their costs are the essence of the trade-offs and getting those trade-offs right. We ought to examine these trade-offs rather than select one arbitrarily.
Gilbert White, sometimes referred to as the “father of floodplain management,” chaired an LBJ-era federal commission that concluded the “use of flood plains involving periodic damage from floods is not, in itself, a sign of unwarranted or inefficient development. It may well be that the advantages of flood plain location outweigh the intermittent cost of damages from floods. Further, there are some kinds of activity which can only be conducted near a watercourse.”
3. What hard evidence do you have? Clearly, science and our understanding of cause and effect must underlie our choices among alternatives and their relative trade-offs. Uncertainty will be omni-present, but we should not assume worst or best cases.
Sowell’s commonsense observations find expression in a set of principles that have guided consensus policymaking since President Reagan codified them by executive order in 1981. These principles have been reasserted by Presidents Clinton, Bush (43), Obama and Trump and are equally applicable for regulatory or budgetary decision making.
Flood resilience should be meaningfully informed by public input and federalism — this means rigorous analysis of all feasible alternatives, unbiased assessment of costs and benefits and application of objective, widely accepted scientific data.
The federal government should hew to roles that do not usurp the powers of states and localities; nor should it impose regulatory burdens unless explicitly mandated in Acts of Congress.
We’ve previously criticized recent attempts to pursue flood resilience through the federal government.
We critiqued the now-revoked Federal Flood Risk Management Standard (FFRMS) and challenged the House-passed “PREPARE Act.” Neither FFRMS nor the PREPARE Act were consistent with the principles needed to guide and protect us from adopting misinformed and wasteful resilience schemes. Both proposals cast aside cost-benefit analysis and accepted science, adopted arbitrary responses, eschewed meaningful public participation and sought to impose nebulous federal regulations on the activities of private and non-federal government entities.
These two proposals were just the beginning of loading the message “to distract the watchdog of the mind” and now by comparison seem quite modest. Almost overnight we have seen the advent of the “Green New Deal’ in which transformation of the entire energy base of the world’s largest economy is trumpeted without a jot or tittle of short pencil, cost benefit analysis.
Sen. Kirsten Gillibrand (D-N.Y.), a member of the Committee on Environment and Public Works, recently made a plea to committee Chairman John Barrasso (R-Wyo.) to integrate the aspirations of Green New Dealism into federal infrastructure. Ironically, this committee has a long and admirable devotion to cost-benefit analysis, particularly as it relates to water projects. The committee now has a grand opportunity to reassert that dedication to the rational principles discussed here.
Unfortunately, there are some who strenuously oppose these commonsense principles. Too often these contrarian voices represent narrow interests that desire specific, arbitrary solutions that exclude competitive alternatives for principled and operational flood resilience. Successfully increasing resilience depends on thoughtful consideration of all feasible measures and then selecting the one that gives us the best payoff in excess of costs. We should budget for such policies and projects.
A rational pursuit of resilience would follow Sowell’s formula to analyze alternatives, assess costs and benefits and apply objective and widely accepted science. We continue to believe in the fundamental truth that there are no solutions — only tradeoffs. Recognizing and dealing with the trade-offs is the only way we will ever achieve politically viable and effective, economic resilience.
Larry J. Prather is an independent consultant and was assistant director of Civil Works for the U.S. Army Corps of Engineers.
Dan Delich co-founded the Floodplain Alliance for Insurance Reform and worked previously as a congressional staffer and U.S. Environmental Protection Agency analyst.