Over the last week or so, you may have seen articles in the newspaper, and then an editorial may lead you to believe that we have our head in the sand, as if we suggest we should not prepare, that nothing is changing.
Not true, not accurate.
We do not question that change is occurring. We question preparing now for ONLY the worst case scenario of 1.5 meters – almost 5 feet of sea level rise in 100 years. Our suggestion, which we provided to the Committee in April 2012 and is again in our position paper last week, is for a more measured approach of planning for a half meter and then carefully monitor the actual rate of sea level rise. Here is our letter dated August 9, 2013:
Thank you for the opportunity to participate in the Sea Level Rise Committee. The Home Builders Association of Delaware (HBADE) is committed to short and long term statewide planning for storm emergencies and science-based sea level rise.
HBADE is a housing and business advocacy association representing more than 400 Delaware businesses with nearly 8,000 employees. As such, we are committed to creating a business friendly and vibrant economy for our state. By necessity our association is a professional volunteer organization that now spends the bulk of our volunteers’ time reviewing DNREC proposed and enacted regulations – much more than changes for all other State and County bodies. The recent increase in DNREC regulatory proposals, from sea level rise, storm water management regulations, flood plain, to Energy Code, and Watershed Implementation Plans have far reaching unintended consequences to Delaware’s economy. These unintended consequences of DNREC actions are directly related to Delaware’s struggling economy, business and job growth, and real estate values. Although the housing economy is improving, growth is slow and can easily be upset by numerous changes to the local community.
The Delaware Sea Level Rise Advisory Committee “Committee” has developed a recommendation report “Recommendations for adapting to Sea Level Rise in Delaware,” in which it provides a series of environmental problems that may result from possible sea level rise within the next 100 years. As such the Committee has provided Delaware with a series of preferred adaptation strategies that can be used to adapt to – and mitigate for – potential sea level rise. While HBADE is committed to working with the State to ensure there is rounded discussion of issues and impacts, we are concerned with several determinations that have come out of this research. We believe no action should be taken on recommendations without full review by the public and the Delaware General Assembly. It is unclear if DNREC is authorized to take any action under the Delaware Code.
Our concerns begin with the ongoing effort by the State to portray Delaware to have 3’ – 5’ (1 – 1.5 meters) – of sea level rise by 2100 and the resulting negative economic impact of using the unscientific and faulty models of measurements. Based upon the information produced by the SLR Committee, it is evident that DNREC’s approach will stigmatize our Delaware coastal areas and cost citizens of Delaware greatly for an event that current science indicates may not happen over the course of 87 years. This includes changing how communities are planned, financed and developed, mortgage financing requirements, payments of additional flood insurance, loss of ability to construct or sell homes in the stigmatized areas assumed to be, and identified as being subject to sea level rise, and changing how infrastructure is invested in areas assumed to be below the rise levels. Is it worth the cost to our local economy to have the State and their scientific agency (DNREC) promote the permanent flooding of 11% of the States land, which is equivalent to 20,000 dwellings lost, the loss of all state tidal wetlands and the loss of entire communities?
Current scientific data shows 12” of sea level rise during the last century. This data now shows a slight increase and projection of 13” of sea level rise this century. HBADE understands that the environment is ever changing and is dedicated to Statewide planning for 19.5” (.5 meters) of sea level this Century which equals 50% more rise than what current science shows. We also stand behind the effort for continued monitoring of this issue and adapting programs, policies and other efforts as data changes.
Unfortunately, since Delaware is utilizing planning for worst case scenarios, rather than implementing an adaptive management approach to possible sea level rise, we feel the current path taken will lead to the destruction of the Delaware coast and its economy.
We request the State discontinue an opinion-based narrative and web site describing the Delaware coast to be under water. The degree of sea level rise is a projection and is not based on conclusive and universally agreed comprehensive science. As such Delaware must be cautious with accepting positions and policies that unduly impacts the State’s economies while yielding minimal environmental benefit. HBADE is thankful for the opportunity to comment on this issue and our membership is more than willing to discuss these concerns in more depth at your convenience