National Flood Policy—ASFPM 2015 Recommendations
O. Disaster Management & Assistance
O.1. Ensure that post-disaster interagency
mutual aid efforts are structured to easily allow
local floodplain management and flood hazard
mitigation needs to be addressed
a) Explicitly allow substantial damage
determinations and floodplain permit
assistance to be eligible for
reimbursement under PA which would
make EMAC a more viable approach
b) Encourage all states to have laws that
allow in-state mutual aid which addresses
liability and credentialing of volunteers
c) Establish mutual aid programs for
floodplain managers within all ASFPM
chapters.
[FEMA, states, ASFPM Chapters]
Interagency mutual aid programs can be very helpful
to help address floodplain management issues postdisaster. However EMAC, which allows interstate
mutual aid, doesn’t work well primarily because
FEMA has a policy that specifically disallows
substantial damage determinations to be
reimbursed under PA. In states where the ASFPM
chapter has facilitated in-state mutual aid,
substantial damage determinations in particular
have been done better and faster (Oklahoma, Ohio,
Georgia, etc.)
O.2. NO federal disaster assistance program or
mitigation program should ever be 100% federal.
There must be at least a minimal amount of nonfederal cost-share to ensure state/local
commitment. [FEMA and other Federal Agencies
providing post-disaster resources]
ASFPM has a core belief that floodplain
management and by extension – disaster
management/assistance, etc is the joint
responsibility of the federal, state and local level.
Accordingly, all should contribute to their recovery.
O.3. Make all federal agency disaster assistance
contingent upon the community and state having
a current hazard mitigation plan and community
participation in any available pre-disaster
mitigation program for which hazards pose a
significant threat in the plan
a) For significantly flood prone
communities, assistance should be
contingent on NFIP and CRS
participation, compliance, and
maintenance of insurance for structures
in the SFHA
b) For small and under-resourced
communities and tribes, ensure
availability of technical assistance to
initially help them with participation in
the mitigation program(s)
[FEMA and other Federal Agencies providing
post-disaster resources, States, Communities]
O. 4. Improve the capacity of the JFO to deliver
mitigation programs timely and effectively
Flood losses continue to increase. Disaster
assistance has been identified by many policy
experts as a primary driver to not changing behavior
of communities and individuals to be more resilient.
Communities should participate in all voluntary
programs that help reduce the risk of a particular
hazard they are vulnerable to before federal disaster
aid is provided.
NFPPR Combined comm rec and comments
JFO operations are inconsistent and generally
provide poorly timed and/or inadequate mitigation
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National Flood Policy—ASFPM 2015 Recommendations
a) Improve the efficiency and delivery of
HMTAP by allowing FCOs to approve
requests consistent with the state’s
mitigation strategy versus FEMA Regions
or FEMA HQ.
b) Require FCOs to be trained in mitigation
programs and include mitigation program
delivery goals as part of their personnel
evaluations
c) Ensure that JFO operational goals equally
value the effective delivery of hazard
mitigation programs as the delivery of
disaster recovery programs
d) Study and develop consistent national
minimum recommendations for
mitigation program staffing at JFOs
e) Establish a goal and plan/process for
supplementing state capacity for the
expedited acquisition of flood prone
buildings within six months of the flood
event if a state includes acquisitions as
part of its mitigation strategy.
f) Require that for every PA Project
Worksheet that at least one mitigation
measure is identified, regardless if it is
eligible for PA funding, and require that
such data be shared with the property
owner and community.
g) Ensure that all JFOs have capability to
analyze existing flood hazard data and
develop ABFEs to guide rebuilding. ABFEs
should be developed in all areas where
existing flood data is insufficient and/or
outdated.
[FEMA, States]
O.5. Ensure that actions undertaken pursuant to
emergency action plans do not cause adverse
flood impacts on other properties in the
community or other communities, or on natural
floodplain function and storage.
[Federal Agencies, States, Communities]
O.6. Work with all federal agencies to ensure
post-disaster policies and programs are
consistent in supporting long-term flood loss
NFPPR Combined comm rec and comments
resources. The operational goals of JFOs and FCOs is
usually to close the facility as fast as possible and do
so with as little cost as possible. There are several
improvements that can be made to make mitigation
program delivery successful.
The first step to make 406 mitigation successful is to
write up mitigation measures as part of the project
worksheet process. That also means that
knowledgeable mitigation staff must be embedded
into PA-PW teams.
When the levee in Cairo was blown (Mississippi
River in 2011) up the properties that were flooded
already had easements that allowed them to flood.
Such foresight and thinking should go into all
emergency protective measures. Entities
undertaking protective measures will and should
continue to be liable for damages that occur on
other properties due to their actions as the “act of
God” defense is largely not valid as such events are
predictable.
More recently, the White House has established, as
a matter of national policy, several directives
towards resilience and sustainability. This will be a
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National Flood Policy—ASFPM 2015 Recommendations
reduction, always consider non-structural
alternatives, include national
resilience/sustainability goals, ensure consistency
with the new PG&R, and factor in climate change.
a) Require that all PL 84-99 projects
consider non-structural measures
b) Require all federal investments in
rebuilding/reconstructing critical facilities
be protected at least to the 500-year
flood level plus account for impacts of
future conditions including climate
change
[FIFM-TF, MIT-FLG, Federal Agencies]
O.7. Establish an independent board similar to
the National Transportation Safety Board, to
investigate disasters; collect data; analyze the
damages, causes and economic, social and
environmental impacts; evaluate effectiveness of
government programs and make loss reduction
recommendations. The board’s
recommendations should be made public through
a report for each event. [FIFM-TF, MIT-FLG,
Congress]
O.8. Develop mitigation related metrics that are
used to measure the success of a post-event
disaster recovery to be used as an indicator of a
successful disaster management and recovery.
[FEMA, MitFLG, USASCE, NRCES, NOAA, DOT]
O.9. Develop an effective and expedient process
in the post-disaster environment that the state
and/or FEMA can review states and communities
for compliance with NFIP requirements and
quickly impose sanctions if necessary. [FEMA,
States]
focus of agencies until at least the end of this
administration if not beyond.
O.10. Develop and require detailed tracking and
enforcement to carry required flood insurance
triggered by the acceptance by disaster assistance
including disaster loans (ie., SBA), IHP and PA
funds post-event.
a) Flood insurance waivers requested by
State Insurance Commissioners should
never be approved by FEMA Regional
Administrators as flood insurance
through the NFIP is widely acceptable.
Recent FEMA GAO and IG reports on disaster aid
verification shows inconsistency by FEMA and states
in verifying whether disaster assistance should be
provided to IHP and PA applicants; the OIG report
indicates that the problem may be worse for PA
recipients.
This is a recommendation that had been made by
Bill Hooke with the American Meteorological Society
and others like Gen Galloway.
The national mitigation framework exists as part of
the national planning framework. However, what
seems to be missing are performance metrics.
In the post-disaster environment, states can make
poor policy choices and establish policies that
conflict with the NFIP. Some communities choose
not to perform substantial damage determinations.
In these situations, FEMA must be able to act quickly
to warn of and impose sanctions if necessary.
[FEMA, SBA, HUD, States]
NFPPR Combined comm rec and comments
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National Flood Policy—ASFPM 2015 Recommendations
O.11. Foster productive recovery partnerships by
providing pre-disaster exercises on rebuilding
with resilience for Federal staff, state agencies,
and tribal, territorial, and local leaders in
vulnerable areas, including on resources,
requirements, and opportunities. Exercises
should be based on strategies identified in local
hazard mitigation plans or pre-disaster recovery
plans. [MitFLG, FEMA, States, and other Feds]
The emergency management community effectively
uses exercises to build and maintain capability, yet
these rarely if ever extend to hazard mitigation and
other resilient recovery efforts. By developing
training and exercise focusing on this aspect of
recover, community capabilities can be built and
lead to a faster and more sustainable recovery effort
overall.
O.12. Support/develop/promote apps, crowdsourcing, and social media approaches for postdisaster recovery information dissemination that
includes key mitigation and resiliency actions.
[FEMA, Other NGO Partners (Red Cross, FLASH)]
The way the public receives and processes
information.
O.13. Reform the disaster declaration process to
ensure that the threshold for a federal disaster
declaration is truly based on exceeding state and
local capabilities.
a) Increase per-capita limits to account for
inflation on an annual basis
[FEMA, Congress]
Disasters are being declared at an ever increasing
frequency and this is not necessarily due to the
increasing frequency of events. Several entities
have pointed out to needed reforms in the process
and point out that often declarations do not exceed
state and/or local capabilities.
NFPPR Combined comm rec and comments
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