Was networking today at ULI about a detailed report on Superstorm Sandy. Very high level people and some good ideas were bandied about.
The concept of a Fund for climate resilience investment tax credits seems sound and people are starting to look a micro ways to use CRITCs. For example, as a way for building owners to make their structures more resilient (e.g., raising mechanicals above flood plains and accounting for future sea level rises). Also, retail corridors that need to be more resilient may have a need for a CRITC to help defray the cost of making these areas more resilient.
I do, however, see these micro areas of resilience not the province of the NRF but rather separate CRITC more in the lines of traditional 20-30% ITCs with some restriction to hold a property a certain amount of time, like the historic rehabilitation investment tax credits.