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Hurricane Harvey's record rains were made at least three times more likely by climate change, scientists calculated. Joseph Cannon

'Climate Change' Removed From FEMA's Strategic Plan

Last year, one of the hottest years in modern history, was also the costliest year ever for weather disasters, setting the U.S. back a record-setting $306 billion in spending aid and relief cost.

But it appears the Federal Emergency Management Agency (FEMA), the agency that responds to hurricanes, flooding and wildfires, is ignoring a critical factor that exacerbates these natural disasters: climate change.

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A citizen of Barranquitas, Puerto Rico, returns home with water and food provided by FEMA on Oct. 17, 2017. U.S. Air Force photo by Tech. Sgt. Larry E. Reid Jr.

FEMA to Shut Off Food and Water Aid to Puerto Rico

UPDATE: Since the release of NPR report and a flood of angry reactions from politicians, FEMA said it never intended to stop giving aid to Puerto Rico and will continue to hand out supplies for as long as necessary.

William Booher, an agency spokesman, told the New York Times that Wednesday was not the actual shut off date but rather an internal planning date to evaluate if the island could still justify needing assistance. Booher also told NPR that date "was mistakenly provided."

"This aid is not stopping," Booher told the Times. "There was no, and is no, current plan to stop providing these commodities, as long as there continues to be an identified need for them."

The Federal Emergency Management Agency (FEMA) will "officially shut off" food and water aid to Puerto Rico four months after Hurricane Maria devastated the island.

"The reality is that we just need to look around. Supermarkets are open, and things are going back to normal," Alejandro De La Campa, FEMA's director in Puerto Rico, told NPR. "If we're giving free water and food, that means that families are not going to supermarkets to buy."

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A patient crosses the brow of a ship docked pierside in San Juan, Puerto Rico. U.S. Department of Defense

Hearing with San Juan Mayor Cancelled, Puerto Rico Confirms 911 Post-Maria Cremations

The House Committee on Homeland Security abruptly cancelled Wednesday's hearing with FEMA Administrator Brock Long on the federal government's response and recovery efforts for recent disasters, including hurricanes Harvey, Irma and Maria and the wildfires in the West.

San Juan Mayor Carmen Yulín Cruz, who has been highly critical President Trump and FEMA's relief efforts in Puerto Rico, arrived in Washington, DC yesterday after being invited to testify at the hearing. In a video posted to social media, she raised questions about the sudden cancellation.

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I’m a Librarian in Puerto Rico, and This Is My Hurricane Maria Survival Story

By Evelyn Milagros Rodriguez, University of Puerto Rico—Humacao

I've always been fascinated by storms, particularly Puerto Rico's own history of them. I think it's because I was born in September 1960 during Hurricane Donna. In its wake, that storm left more than 100 dead in Humacao, the city where I am now a special collections librarian at the University of Puerto Rico.

In 1990, Israel Matos, the National Weather Service Forecast Officer in San Juan, told me that "the tropics are unpredictable." That comment only increased my interest in storms. Now, with the people of Puerto Rico still reeling from Hurricane Maria more than a month after it hit the island, his words seem prescient.

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Taken on Oct. 11 in Barrio Maní, Mayagüez, Puerto Rico. Cathy Mazak

'We Are Not OK': A First-Hand Account of Hurricane Maria

By Cathy Mazak

I'm so happy to be able to communicate with you again. As many of you know, I live in western Puerto Rico. In this post I want to tell you a little about my family's experience with Maria, and how you can help Puerto Rico.

On Thursday Sept. 21, when the sun came up, I looked out our front door at a wintery landscape. There was not one leaf on one tree in all the tropical forest that surrounds our property. Instead, the walls of my house were plastered with one-inch-by-one-inch pieces of leaves. It was as if they had been stripped off the trees, chopped in a food processor, and coated onto our house with a pressure washer.

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Federal Emergency Management Agency Administrator Brock Long

FEMA Chief Says 'We Filtered Out' San Juan Mayor After She Pleads 'We Need Water!'

The administrator of the Federal Emergency Management Agency (FEMA) dismissed the mayor of San Juan's vocal criticism of the Trump administration's Hurricane Maria relief efforts in Puerto Rico.

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Sgt. Jose Ahiram Diaz-Ramos/Flickr

FEMA Scrubs Data About Puerto Rico's Lack of Water and Electricity

On Wednesday, roughly two weeks after Hurricane Maria struck, just 50 percent of Puerto Rico had access to drinking water and only 5.4 percent had electricity. That information was clearly displayed on Federal Emergency Management Agency's (FEMA) website on disaster relief efforts in the U.S. territory.

But the next day, as first noticed by the Washington Post, those two critical pieces of information were removed from the website.

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Extreme Weather Cost U.S. Taxpayers $67 Billion

By Erin Auel and Alison Cassady

One of the most visible and immediate ways climate change has affected—and will continue to affect—Americans is through extreme weather exacerbated by rising global temperatures.

Aerial image of flooding in New Orleans following Hurricane Katrina in 2005.

Between 2005 and 2015, the annual average temperature in the U.S. exceeded the 20th-century average every year, with increases ranging from 0.15 degrees Celsius to 1.81 degrees Celsius above normal. Moreover, the federal government's most recent National Climate Assessment concludes that as temperatures continue to rise, extreme weather events and wildfires will increase in frequency and intensity.

Climate change will worsen heat waves, winter storms, and hurricanes. It will exacerbate extremes in precipitation, leading to more severe droughts and wildfires in some areas and heavier rainfall and flooding in others. And when the damage is done, taxpayers will be left to pick up the bill.

When extreme weather strikes and state and local governments are overwhelmed, the federal government must often intervene. In the worst cases, the president can declare an emergency or a major disaster, which releases federal funds for the damaged areas. The Federal Emergency Management Agency (FEMA) provides financial assistance to local, tribal and state governments, as well as individual households, after the president declares an emergency or major disaster.

The Center for American Progress (CAP) examined FEMA data on weather- and wildfire-related disaster declarations between 2005 and 2015 to identify trends in FEMA disaster spending, which is funded by U.S. taxpayers. CAP found that:

  • Between 2005 and 2015, FEMA issued more than $67 billion in grants to assist communities and individuals devastated by extreme weather and wildfires. Overall, FEMA spent about $200 per U.S. resident for disaster assistance during that time period.
  • FEMA provided the most disaster assistance to Louisiana and New York, which, combined, received more than half of the agency's total assistance over the 10-year period due to damage caused by Hurricane Katrina and Hurricane Sandy, respectively. Texas, Mississippi, and New Jersey rank third through fifth for FEMA disaster spending between 2005 and 2015.
  • The states that received the most FEMA disaster assistance spending per capita were Louisiana ($4,345), Mississippi ($1,607), North Dakota ($843), and New York ($807). In North Dakota, unprecedented flooding events in 2009 and storms in 2011 caused substantial damage, driving up per-person costs among a smaller state population.

These findings likely underestimate the true federal cost—and thus the cost to taxpayers—of extreme weather. FEMA provides assistance in response to the worst natural disasters—those that triggered emergency and major disaster declarations. As a result, the findings do not include the costs of smaller but still destructive storms, costs borne by private insurers, and other government spending, such as the U.S. Department of Agriculture's disaster assistance program.

As the climate warms, these types of extreme weather and wildfire events could impose an even greater burden on American communities and taxpayers. In order to prepare for this reality, communities must invest in climate-resilient infrastructure and integrate climate considerations into their development plans.

Findings: FEMA Is Spending Billions on Natural Disasters

Between 2005 and 2015, the president issued 832 separate emergency or disaster declarations for which FEMA provided either public assistance—defined as funding for state, tribal, and local governments—or individual assistance in the form of grants typically made to homeowners and renters whose home damage was not covered by homeowners insurance.

Between 2005 and 2015, FEMA spent $67.7 billion on household and public assistance in response to presidentially declared emergencies and major disasters. Of this amount, $14.36 billion was spent on individual and household assistance, and public assistance outlays to state, tribal and local governments made up the rest—$53.31 billion.

During this 10-year period, there were extreme weather and wildfire events in all 50 states, the District of Columbia, and several U.S. territories and throughout all seasons. Severe storms were the most frequent cause of disaster declarations, with 470 distinct declarations across the examined time period.

Although less common than severe storms, hurricanes caused the most damage. Between 2005 and 2015, FEMA spent $49.5 billion on public and individual assistance to help communities recover from hurricanes. FEMA spent $12.7 billion for assistance related to severe storms over the same 10-year period.

Center for American Progress

Hurricanes accounted for eight of the top-10 costliest disaster declarations between 2005 and 2010, including hurricanes Katrina, Sandy, Ike, Wilma, Rita, Gustav, Irene and Isaac.

Center for American Progress

Accordingly, although the total assistance by state varied widely, FEMA directed significant disaster spending to states that experienced historic hurricane damage during the period examined. These states include Louisiana and Mississippi, where Hurricane Katrina hit hardest in 2005, and New York and New Jersey, where Hurricane Sandy landed in 2012.

Nationwide, FEMA spent more than $22 billion in assistance responding to Hurricane Katrina, including allocations for states that provided assistance related to evacuations. The agency provided nearly $16 billion in household and public assistance grants in response to Hurricane Sandy.

Non-hurricane events can cause significant and costly damage as well. In August 2016, Baton Rouge, Louisiana, experienced historic flooding from torrential rainfall. As of Aug. 23, the floods had killed 13 people, and more than 100,000 people had applied for federal assistance. Preliminary analysis from Climate Central and the National Oceanic and Atmospheric Administration found that increased temperatures due to climate change increased the likelihood of intense downpours in Louisiana by 40 percent.

Floods are among the most costly extreme weather events that can hit an area, as they can destroy large areas of property and can take a long time to recede. Between 2005 and 2015, flooding caused eight of the 10 costliest non-hurricane disaster declarations and occurred across several different regions.

Looking at the per-capita costs of extreme weather reveals that these disasters have a profound impact on individuals and communities. Louisiana received $4,345 per person in FEMA disaster spending between 2005 and 2015, the most of any state. Mississippi received the second-highest amount per capita—more than $1,600. Overall, FEMA spent about $200 per U.S. resident for disaster assistance between 2005 and 2015.

Damage is not just limited to coastal areas. States in the central U.S. with relatively small populations have been hit hard by extreme weather and subsequently received significant assistance from FEMA. North Dakota, for example, ranks third for per-capita FEMA assistance over the analyzed decade due largely to eight distinct flooding events. Iowa ranks fifth for per-capita FEMA spending and seventh for total spending because of severe storms that caused major statewide flooding in 2008. Of the 10 states with the highest per-capita spending, half are located in the central U.S.

Conclusion

Extreme weather is already costing taxpayers and the federal government valuable public dollars and resources. Americans have recognized these costs; in a 2015 New York Times survey, 83 percent of respondents said that unmitigated climate change poses "a very or somewhat serious problem in the future."

Because of the damage already caused to the climate, communities in the U.S. and around the globe will experience more frequent and intense extreme weather events, even if world leaders take immediate action to cut greenhouse gas emissions.

Faced with this reality, FEMA has proposed a rule that would establish a deductible for disaster assistance in order to encourage states to make investments in resilience measures before disasters occur. This rule could incentivize states to invest in climate-smart infrastructure to minimize the financial and human toll of extreme weather.

The FEMA proposal is one among many efforts to push communities to better prepare for storms, floods, and other natural disasters—an effort made even more urgent because of climate change—rather than focusing only on responding to a disaster's aftermath. Resilience, however, is only one prong in a coordinated response to climate change. The world must also focus on mitigating the worst impacts of climate change by reducing greenhouse gas emissions and transitioning the global economy to cleaner, low-carbon forms of energy.

Methodology

CAP examined FEMA data on presidential declarations of major disasters and emergencies between 2005 and 2015. The data reflect the two primary disaster declaration types: major disaster and emergency. CAP analyzed FEMA data on public and individual/household assistance spending in response to these declarations. The data were last updated on July 12.

For the per-capita analysis in Table 3, CAP used population data obtained from the U.S. Census Bureau. To calculate the per-capita costs by state, CAP averaged the state population totals from 2005, 2010 and 2015. The national per-capita figure in Table 3 reflects FEMA disaster assistance to all 50 states, the District of Columbia, and the U.S. territories.

CAP developed a methodology for excluding and including disasters to ensure the analysis only includes declarations that reflect the types of events that could become more common with unmitigated climate change.

We included public and individual assistance payments made in response to major disaster declarations and emergency declarations for the following types of incidents: coastal storms, drought, flooding, freezing, hurricanes, mudslides from flooding, severe ice storms, severe storms, snow, tornadoes, typhoons and wildfires. We excluded public and individual assistance payments made for the following types of incidents that occurred between 2005 and 2015: water main breaks, terrorism, explosions, earthquakes, chemical spills, tsunamis, the 2009 presidential inauguration, bridge collapses and volcanoes.

Massive Wetlands Destruction Project Still Pending

Water Protection Network

By George Sorvalis

The Obama Administration is facing mounting pressure to release an environmental analysis that could recommend building the controversial New Madrid Levee, a component of the St. John's Bayou and New Madrid Floodway project in South East Missouri.

The pressure is coming from Missouri’s Sen. Blunt, who has placed a hold on President Obama’s nominee to run the U.S. Environmental Protection Agency (EPA), Gina McCarthy, until the U.S. Army Corps of Engineers (USACE) publicly releases its newest environmental analysis for the project, called a Draft Environmental Impact Statement.

In Big Oak Tree State Park is a noble cypress stand in a thousand-acre bottomland hardwood forest in the New Madrid Floodway. The USACE proposal to close the gap would damage 75,000 acres of productive floodplain habitat while putting Cairo at greater risk of flooding.

The public release of the analysis has been delayed due to major differences between the USACE and the resource agencies (like EPA and U.S. Fish and Wildlife Service) over the number of wetlands impacted and the adequacy of the mitigation plan to offset those impacts.  

While Missouri landowners who farm in the New Madrid Floodway want to see this project move forward, pubic officials in Illinois and Kentucky (who fear the New Madrid Levee will complicate federal flood response) and environmentalists (who fear the New Madrid Levee will collapse the fishery of the Middle Mississippi River) are urging the Obama Administration to put an end to the project once and for all.

The New Madrid Floodway

The USACE has built thousands of miles of flood control levees on the Mississippi River. It has also built a few floodways—areas where the USACE diverts floodwaters to take pressure off of its levees. Shaded in red here is the New Madrid Floodway. The levees that surround the floodway, shown in red, are 60 feet high and totally surround the New Madrid Floodway, except for a quarter-mile gap at New Madrid. This quarter mile gap is the yellow "Outflow" line on the map. The most controversial element of the St. Johns Bayou New Madrid Floodway Project is a new proposed levee, come to be known as the New Madrid Levee, to close that quarter-mile gap.

Closing the Gap Will Increase Flooding Risk

Closing this gap with the proposed New Madrid Levee will increase the flooding threats to a dozen riverside towns by encouraging more agribusiness and development in the New Madrid Floodway, thereby discouraging its use. Throughout history, the USACE has faced significant obstacles when it tries to activate the New Madrid Floodway, and the new levee will only add another obstacle.

To activate the New Madrid Floodway, the USACE fills in pre-drilled holes in the existing levees with explosives and literally explodes the levee at Birds Point, just south of Cairo, IL. The water flowing into the floodway then relieves pressure on the entire flood control system, and reduces flood heights regionally in Cairo and other nearby towns.

In 1937, the first time the USACE used the floodway, it had to call in the National Guard to fend off armed Missouri floodway farmers, even though the federal government has compensated floodway landowners by purchasing flowage easement to flood their farmland. In 1983, when the USACE was preparing to use the floodway, Missouri floodway farmers sued and the judge issued an order preventing the USACE from using the floodway until April of the following year. Fortunately floodway activation levels were never reached. But during the great Mississippi River Flood of 2011, activation levels were reached, then surpassed before the Corps activated the floodway. While Cairo and other towns that were under mandatory evacuation orders saw flood heights start rapidly lowering, the Len Small Levee protecting the City of Olive Brach breached before the Corps activated the floodway, destroying 50 homes and causing millions in damages.

Cairo, IL, Paducah, KY, and Sikeston, MO, are some of the towns that will face greater flooding risks if the USACE builds the New Madrid Levee. According to the Corps’ 2006 Environmental Analysis, “Non-operation of the floodway during project flood conditions means that many citizens outside the floodway would not be provided the level of flood protection that they are authorized to have by law.” The USACE models show higher river stages as far as 40 miles up the Ohio and Mississippi Rivers, with those towns experiencing “overtopping of floodwalls and/or levees and flooding.” Hickman, KY, will see an additional 3.9 feet; Cairo an additional 4.6 feet and Paducah, KY, an additional 1.8 feet of flooding.

As flood waters were rising in the Spring of 2011, on behalf of Missouri floodway farmers, the State of Missouri filed a restraining order to prevent the USACE from using floodway, and the federal judge heard the case on April 28.  On April 29, the federal court denied the order and Missouri appealed.  On April 30, the 8th Circuit Appellate Court also denied Missouri’s restraining order before Missouri appealed to the U.S. Supreme Court. All the while floodwaters are rising.  On May 1, the U.S. Supreme Court denied the restraining order and the USACE was "cleared" to use the floodway, but it was too late for Olive Branch—the Len Small Levee had breached, sending floodwaters to inundate the town.

The flooding of Olive Branch, MO.

According to Illinois Department of Natural Resources Flood of 2011 Alexander County Flood Damage Reduction Study, “If the floodway had been activated prior to a stage of 61 feet, millions of dollars in flood damages could have been avoided, including the damage to the Len Small Levee, excessive seepage in Cairo and direct flood damages in unprotected Alexander County.”  In total, 50 homes were completely lost and the community is currently working with Federal Emergency Management Agency on a community-scale buy out and relocation.

Public Officials Oppose New Madrid Levee

Due to the increased flooding threat the New Madrid Levee would bring to river communities in the region, pubic officials are speaking out against the project.

Cairo Mayor Coleman testified April 8 at the Mississippi River Commission Public Meeting in Cape Girardeau, MO. He stated:

By building the New Madrid Levee we are inviting more development to occur in the New Madrid Floodway, which will undoubtedly make it harder for the Commission to use the floodway in future floods, putting our town and others at greater risk of catastrophic flooding.

Other public officials have also written in opposition.

In a 2012 letter, Michael Caldwell, the chairman of Alexander County Board of Commissioners wrote:

I urge you to do everything you can to ensure that this project is stopped for good and that the basic safety needs of Alexander County, the City of Cairo, and surrounding communities are prioritized over a levee closure to benefit a few wealthy landowners.

In a 2012 letter, Monte Russell, the chairman of Pulanski County Board of Commissioners, wrote:

This federally funded Corps of Engineers project jeopardizes the safety of our community by increasing our risk of catastrophic flooding.

In a 2012 letter, Sam Johnson, mayor of Mound City, IL, wrote:

Federal flood damage reduction investments in the region should instead focus on protecting people and recognize the critical value and function of the New Madrid Floodway in doing just that.

In a 2012 letter, Wayman A. Butler, junior mayor of City of Mounds, IL, wrote:

Use of the New Madrid Floodway saved our community from catastrophic flooding during last spring’s flooding along the Mississippi River.

In a 2012 letter, David Willis, chairman of the Len Small Drainage & Levee District wrote:

This project would trade away our town’s safety to allow large landowners to intensify agricultural production and development behind the new levee, within the New Madrid Floodway in Missouri.

Environmental Impacts

Thanks to the thousands of miles of levees on the Mississippi River, that quarter-mile gap represents the last significant connection the Mississippi River has to its floodplain in the whole state of Missouri and for hundreds of miles. This connection is absolutely critical to sustaining the fish population of the Mississippi River. During high water, the bottom portion of the New Madrid Floodway floods and fish enter the floodway. When the water recedes, thousands of acres of ponds remain, creating a tapestry of fish nurseries where fish can grow where the water is warmer, calmer and shallower than the cold swift currents of the mighty Mississippi. Closing the gap will eliminate this habitat and likely lead to a collapse of the fishery of the entire Middle Mississippi River.

According to the U.S. Fish and Wildlife Service’s 2000 Fish and Wildlife Coordination Act Report:

The Service opposes the St. Johns Bayou and New Madrid Floodway alternative because it would cause substantial, irretrievable losses of nationally significant fish and wildlife resources, and greatly diminish rare and unique habitats found in southeast Missouri.

A 2011 email from EPA’s Region 7 Watershed Planning & Implementation Branch Manager said:

[It] could potentially have the largest negative impact on wetlands and streams of any project ever proposed in Region 7.

Even the USACE's own Independent Review Panel concluded in its 2011 Final External Peer Review Report that “the loss of this last remaining connection and its ecosystem functioning would be the ‘straw that broke the camel’s back’ in terms of the total cumulative impact to the natural ecosystem.”

A 2011 letter from the U.S. Department of Interior to the Assistant Secretary of the Army for Civil Works asserts that the project is not in our national interest and should be abandoned: 

The primary project purpose is to reduce flooding for the intensification and diversification of agriculture production, which comprises 90 percent of the project's economic benefits. Improving agriculture production is an important value, but it does not depend on draining wetlands and severing the river-floodplain connection... Unless the purpose and alternatives for the New Madrid project have changed since the last evaluation, the Department does not believe it is in the public interest to engage in yet more environmental analysis of this project.

The EPA estimated about 45,000 acres of wetlands impacts, in sharp contrast to the 6,000 acres the USACE asserts. Putting this into context with other projects—if you take the annual average amount of permitted wetlands losses, then double that number, you still would not reach the number of wetlands this project would destroy. Based on this one statistic alone, this project should not be permitted to move forward.

Economic Impacts

Investing millions of tax dollars to build a levee, to protect an area designed to be intentionally flooded, just does not make sense. In this era of austerity, newspapers have been quick to pick up on how wasteful a project this is:

According to an article in the The Washington Post, "A Watery waste of Taxpayers’ Money":

They want the federal government to spend taxpayer money encouraging economic activity in a zone it is obligated to flood during high-water events.

According to a letter to the editor from from the Great Rivers Environmental Law Center, "New Madrid Levee Project Would Misuse Tax Money," published in the St. Louis Dispatch:

We think the best resolution is no project, or one focused on protecting homes and schools. A more focused project could be accomplished at a fraction of the cost, and would not sever the Mississippi River from its floodplain in Missouri, destroying 50,000 acres of wetlands.

According to a 2002 email from the USACE Legislative Management Chief:

[The project is] an economic dud with huge environmental consequences.

And according to a 2000 email from a recently retired USACE employee:

You just can’t find enough economic justification to build the essential parts of the project, let alone pay a reasonable amount of mitigation of the environmental losses.

Project Status

In 2007, a Federal District Judge threw out the USACE environmental analysis for being out of compliance with environmental laws and actually ordered the USACE to remove project features that it had already constructed. The judge stated in his opinion, “The Corps of Engineers has resorted to arbitrary and capricious reasoning—manipulating models and changing definitions where necessary—to make this project seem compliant with the Clean Water Act and the National Environmental Policy Act when it is not.”

Today, the USACE is on the verge of releasing to the public its "revised" analysis, but is in dispute with the EPA and the Fish and Wildlife Service on the number of wetlands impacted and the adequacy of the project’s mitigation plan to offset the environmental damage. Apparently frustrated by the delay this dispute is causing, Sen. Blunt (R-MO) is pressuring the USACE to release the revised study by placing a hold on President Obama’s nominee to head the EPA, Gina McCarthy. Sen. Blunt has stated publicly that he simply wants resolution and for the agencies to stop arguing among themselves over the facts surrounding the project. "I'm not calling on the Obama Administration to spend a dime, or to build a thing. All these agencies need to do is agree on the facts surrounding a very long-standing project." 

Resolution

The USACE can resolve this dispute immediately by agreeing with the EPA and the Fish and Wildlife Service on the wetlands impacts, fish and wildlife impacts, and appropriate mitigation to replace lost wetlands and fish and wildlife habitat. Fully embracing and incorporating this input from the resource agencies will ensure the USACE provides the public with an accurate accounting of the project impacts, something we know the Corps fell far short of accomplishing in their last study that the federal district court threw out in 2007.  

This full accounting of the environmental impacts would likely preclude the levee from being a project feature, but could still allow the USACE to proceed with project elements that provide flood protection for communities in the St. John's Bayou. If agencies agree on the impacts and the process can move forward, Sen. Blunt will have his decision and a fair vote on well qualified leader like Gina McCarthy as EPA Administrator can also move forward. 

It is by no means a perfect situation to have to sacrifice farmland to save towns, but we can't just build our way out of this mess. It may mean giving just a little of the floodplain back to the Mississippi River. We will get a lot back in return.

You can weigh in by signing a petition urging President Obama to stop the New Madrid Levee and call your Senators to insist that they give President Obama the following message: “Mr. President, do not let Senator Blunt’s hold on EPA Nominee Gina McCarthy force you into letting the Corps of Engineers disregard the sound science of EPA and FWS for this project that has such huge environmental and public safety impacts."

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