FR 2021-01856

The document from the Department of Commerce, specifically the National Oceanic and Atmospheric Administration (NOAA), seeks public feedback on a proposed data collection project aimed at assessing and enhancing financing mechanisms for coastal resilience. This initiative, titled "Coastal Management Needs Assessment and Market Analysis for Financing Resilience," is part of NOAA’s broader efforts to support coastal communities in dealing with both immediate and long-term environmental challenges such as hurricanes and rising sea levels.

General Summary of the Document

NOAA intends to conduct structured telephone interviews with various stakeholders, including coastal managers, representatives from non-profit organizations, academic experts, federal employees, and members of the finance industry. These interviews aim to gather insights on existing coastal resilience funding options, the obstacles these stakeholders face, and potential opportunities for improvement. The ultimate goal is to develop a comprehensive understanding that will guide future resources and partnerships for enhancing coastal resilience activities.

Significant Issues or Concerns

There are several concerns associated with this proposed collection initiative:

1. Ambiguity in Outcomes: The document does not clearly articulate how the information from the interviews will be translated into tangible actions or policy changes. This lack of clarity raises questions about the practical utility of the endeavor.

2. Limited Methodology for Data Collection: The reliance solely on interviews might limit the richness and comprehensiveness of the data. A multi-method approach could enhance the depth of insights gathered.

3. Selection of Participants: The document mentions a relatively small pool of 36 respondents for the interviews without detailing how this sample will ensure a representative cross-section of the diverse coastal management community. This raises concerns about the inclusivity and representativeness of the findings.

4. Lack of Budget Transparency: There is no mention of the budget allocated for this project, which makes it challenging to evaluate the efficiency and value for the proposed activities.

5. Complex Language: Certain parts of the document are described in complex terminology, which might hinder understanding, particularly for engagement with the general public.

Potential Impacts on the Public

For the general public, especially those residing in coastal areas, the outcomes of this initiative could influence the resilience and long-term sustainability of their communities. Enhanced financial strategies and funding mechanisms may directly mitigate the risks posed by natural disasters and climate change impacts. However, the indirect and prolonged nature of these impacts means that immediate benefits may not be apparent to the public.

Positive and Negative Impacts on Stakeholders

For coastal managers and local governments, a successfully executed needs assessment could lead to more accessible funding and improved guidance in resilience planning, thus supporting their efforts to protect communities and ecosystems.

For financial institutions and private investors, the market analysis could reveal new opportunities for investment in innovative funding models for resilience. However, without immediate actionable outcomes from the research, these potential benefits might remain theoretical.

Conversely, the public might view the initiative as another instance of bureaucratic red tape if there are no demonstrable actions following the assessment. Additionally, the absence of specific organization or partner mentions might raise concerns about potential favoritism or lack of transparency in the decision-making process.

Conclusion

While NOAA's initiative to better understand and support coastal resilience financing is commendable, the success of the project hinges on addressing the aforementioned concerns. The effectiveness with which these issues are handled will determine the real-world impact of the proposed research and its ability to facilitate meaningful change for coastal communities and their environments.

In the document under review, financial considerations are minimally referenced, raising several points of concern regarding transparency, scope, and practical utility.

Financial Savings Through Mitigation Investments

One of the notable financial references in the document is an estimate indicating that investing in mitigation can result in a savings of $6 for every $1 spent. This cost-saving ratio highlights the potential long-term financial benefits of such resilience measures, suggesting that proactive investments can be economically advantageous. However, the document does not expound on how these estimations align with the proposed activities or specific budgetary allocations for the information collection itself.

Estimated Financial Burden to the Public

The document specifies that the Estimated Total Annual Cost to the Public is $0. This implies that the information collection activities will not directly burden the public financially. While this is positive, the lack of an articulated budget for the proposed activities could obscure potential costs that may arise indirectly or through other funding channels. Without an explicit budget, assessing whether public funds are being utilized efficiently or whether there are potential areas for financial waste becomes challenging.

Issues Relating to Financial Clarity

One primary issue is the absence of a budget or financial outline within the document, which makes it difficult to ascertain the financial implications of the proposed collection activities. Knowing how funds will be allocated would enhance understanding of the project's scope and help address concerns of potential inefficiencies or mismanagement. Additionally, while the document mentions benefits from mitigation-based funding, it fails to provide a clear pathway of how the gathered information will translate into financed actions or policy changes that ensure these savings effectively materialize.

The reliance primarily on interviews as the method for data collection, with no mention of supplementary methods, may limit the robustness of the collected data. This could result in an incomprehensive or one-sided financial analysis, particularly if the diversity of perspectives in these interviews does not capture the breadth of financial needs and realities across different communities.

Lack of Detailed Financial Planning

The document does not offer detailed insights into how the interviews and resultant data will lead to actionable financial strategies or policies. This paucity of detail can lead to ambiguity regarding the project's utility and effectiveness in addressing the financial challenges faced in coastal resilience efforts. Without this clarity, it is challenging to evaluate the potential impact of any financial conclusions or recommendations derived from the collected data.

In summary, while the document highlights the potential cost savings of mitigation efforts, it lacks comprehensive financial planning details necessary to assess the efficiency and impact of the proposed information collection activities. For stakeholders and the public, a more explicit financial breakdown would enhance understanding and trust in the project's capacity to effect meaningful change in coastal resilience financing.