A. NFPPR - FLOOD MAPPING
(Categorized by sub-topic)
Recommendation
Explanation/rationale
1. Fully fund and implement National Flood Flood hazard area mapping is the backbone of
Mapping Program (NFMP) as directed by this nation’s flood resiliency and sustainability
Congress in the 2012 NFIP Reform [Congress]
efforts. Priority should be placed on enhancing
the map accuracy and completing the flood
hazard mapping for the entire nation
2. Fund map maintenance and regular map updating Once developed, flood maps need to be
as continuation of the National Flood Mapping continually updated tom stay relevant
Program. [Congress]
3. Capture, on an ongoing basis, unmet map needs
from the MapMOD and RISKMAP scoping,
discovery efforts, and input from state and local
partners in order to have and be able to report to
congress an accurate scope of needed mapping
efforts . These unmet mapping needs should also
be summarized by state and county and provided
to the Technical Mapping Advisory Council
(TMAC) for their information and use [FEMA]
An accurate accounting of mapping needs, by
state and county, would need to be produced
and shared with the congress (as well as with
TMAC) so that congress has a clear
understanding of the enormity of the task at
hand and can plan for a continuous funding
stream needed to fulfil the challenge
4. Continue to fund flood mapping & maintenance To make a dent in the flood mapping and
outside of NFIP policy and fee budget to the full maintenance needs, annual funding at a
authorized BW-12 levels ($400 million/year). substantial level is needed.
[Congress]
MAPPING PROCESS AND STANDARDS
5. Utilize
and
implement
the
applicable When the 2014 TMAC recommendations are
recommendations of the 2014 Technical Mapping made available, they will need to be funded
Advisory Council (TMAC) [FEMA, other federal and implemented.
agencies, states, local agencies]
6. Consider establishing TMAC as a long-term or Having TMAC as a permanent council would
insure congress’s access to an independent,
permanent council [Congress]
informed body at any time when the need for
such timely advise would arise
7. Explore potential changes to current FEMA
practice with regards to funding, production,
storage, management, and stewardship of various
data layers used to produce FIRM or other nonregulatory products. These changes could include
NFPPR rec and rationale
Currently, the responsibility for funding,
production, storage, management, and
stewardship of various data layers used to
produce FIRM or other non-regulatory products
all rest with FEMA. This puts an enormous
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FEMA concentrating its focus exclusively on the
development, maintenance, and update of flood
hazard-related data layers and rely on/link to
other needed non-flood hazard related data
layers that currently are (or can potentially be)
under stewardship, managed, maintained by
other federal or state agencies through either
independent or FEMA-supported funding, to
produce FEMA FIRM or non-regulatory products.
Under such proposed scenario, each agency will
only be responsible for the accuracy of the layers
under their stewardship.
a. Flood hazard-related data layers
include, but are not limited to:
i. a fully digital national flood
hazard data layer (Primary
focus);
ii. coastal erosion and riverine
fluvial
erosion/channel
migration zones;
iii. areas protected by dams,
levees, diversions, reservoirs,
and other structural projects
(delineated
simply
by
assuming
the
structural
measure has been removed);
iv. areas with repeat flood
damage claims and adjacent
areas with repeat flooding
histories; and
v. Other special flood hazardrelated layers
b. When not available for some flood
hazard related data, such as fluvial
erosion zones, FEMA should develop
national
program
performance
standards so that data created by
state, local, and other mapping
partners can be readily utilized by
FEMA.
Performance
standards/protocols can be based on
existing state or federal entities that
are already creating some of these
products.
c. FEMA should include various flood
hazard-related data layers (as noted
earlier), where applicable and when
data is available, on FIRM and work
NFPPR rec and rationale
burden on one agency and in many cases leads
to duplication of efforts by other federal and
state agencies that have primary jurisdiction
and expertise over some of these data layers.
This also distracts FEMA’s efforts from ensuring
that an accurate flood hazard layer is produced
and maintained for all the nation’s flooding
sources. Agencies should focus their efforts on
producing and maintaining data layers (rather
than “maps”) for those products under their
traditional stewardship (such as stewardship of
USGS with regards to topographic mapping).
Many state and local land use planning and
regulating agencies are already capable and/or
will soon be capable of producing their own
“maps” through overlaying the hazard layers
important to them on local road maps or best
aerial maps with the community boundaries
they maintain. This will bring about
sustainability of the mapping program and buy
in at the state and local level. While we are not
suggesting that this be implemented over night,
we do believe this could serve as a long-term
vision for future of “flood map” production in
this nation.
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with TMAC and congress to establish
new SFHA zones (such as an “AP”
zone for protected areas, etc) and
locally required regulations (as a
condition to participate in NFIP) to go
with it to discourage economic
growth and exposure in flood risk
areas. Flood insurance premiums for
such zones should be based on actual
risk (i.e., in addition to expected
damage potential, qualified activities
undertaken to buy down the risk,
such as levees, dams, etc., should be
recognized).
d. Non- flood related data layers
include, but are not limited to:
i. topographic/bathymetric
data;
ii. base
maps,
(including
road/street centerlines and
names);
iii. aerial photography;
iv. political boundaries; and
v. other similar data layers.
e. Each data layer should have the
proper supporting metadata, domain
tables,
and
other
necessary
certification and licensing information
consistent with FEMA’s minimum
requirements.
f. FEMA should maintain meaningful
links to those non-FEMA maintained
data sets, utilizing the most
appropriate data sharing protocols,
and ensure that data sets are
available at least until any reference
to them would only be for historical
purposes rather than legal or
insurance purposes.
g. As a long-term vision and a logical
follow up to the proposed changes
discussed above, FEMA should
consider transitioning its “map”
production system to a fully digital
decentralized system. As experience
is gained focusing on management
and maintenance of “flood hazardrelated data layers” versus “flood
NFPPR rec and rationale
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maps” as its primary responsibility
with respect to mapping products,
FEMA, with guidance and assistance
from TMAC and after obtaining
proper authorization from congress,
should move towards a map
processing system where the primary
“mapping” product from the agency
will be the flood hazard-related data
layers. In such a system, preparation
of a “map” through overlaying of
appropriate
mapping
layers
applicable to a state or a local
community, printing on demand, and
distributing such mapping products
can be delegated to qualified
mapping partners based on minimum
requirements
and
guidelines
developed by FEMA as to the
minimum required data layers that
would need to be included on a map,
etc. [FEMA, with guidance from
TMAC]
8. Establish national performance standards for the
development of data layers capturing expected
future-condition flood hazards (as a result of
climate change, projected see level rise, likely
flow increases due to uncompensated changes in
watershed land use, expected permitted
development activities such as cumulative filling
of floodway fringe areas, and other factors
affecting flood–related risks in the future) and
allow inclusion of such data layers on FIRM when
data is available and requested for inclusion on
FIRM by a state or local mapping partner. [FEMA,
with guidance and assistance from TMAC]
To be sustainable, the communities need to
have access to reasonably expected future
condition flood hazards data layers. Coming up
with national standards for production of such
data layers will be important for consistency
and for strategic planning at a national level.
Also allowing and encouraging the
incorporation of such data layers in the
community’s FIRM would make it easier for
those communities, which have such data
available and are willing to regulate at a higher
standard level, to implement such good
practices.
9. Delegate authority and funding for mapping of all
flood hazards on NFIP flood maps to qualified
state and local partners under the Cooperating
Technical Partner (CTP) program. Program should
allow the mapping priorities to be developed by
the authorized state and local partners, with
input provided by FEMA. Program should also
Delegation and stewardship of mapping flood
hazards at the state level (and sometimes even
at a local level) is essential to this nation’s road
to sustainability. We should start this process
through baby steps of delegation to willing CTPs
who are qualified and have track record for
NFPPR rec and rationale
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require the authorized states and local partners such stewardship.
to undertake the mapping in accordance with
standards that equal or exceed FEMA’s standards.
[FEMA]
10. Review and strengthen current CTP guidelines
and qualifications so that those state or local
partners selected for delegation would meet or
exceed the FEMA‘s minimum expectations.
[FEMA]
Strengthening current CTP guidelines would
help both FEMA and CTPs evaluate their
readiness to share the workload in such a way
that it results in a more sustainable system with
a better quality product at a lower price.
11. Require CTP delegated states to develop and
maintain an archival system for all flood map
models for data stewardship and storage in
addition to the Map Service Center. Encourage
and provide funding incentives to all states to
archive flood map data in digital, electronically
transmittable form. [FEMA]
When states are entrusted with production and
maintenance of flood mapping products, they
should be required to maintain an an
independent archival system so that all the
mapping needs of a state can eventually be
fulfilled under the stewardship of that state.
12. Review and strengthen current LOMR Delegation
guidelines and qualifications and expand the
LOMR Delegation Program to allow additional
CTP delegated states and state designated local
authorities who are willing and qualified to
undertake this aspect of program. [FEMA]
Strengthening current LOMR delegation
guidelines would help both FEMA and CTPs
evaluate their readiness to share the workload
in such a way that it results in a more
sustainable system with a better quality
product at a lower price.
13. Consider changing the minimum standard for
designating floodways to the “full conveyance
floodway” concept and continue to allow no (0.0
feet) impact for proposed encroachment into
floodway. A full conveyance floodway includes all
of the area inundated by the 1% annual chance
flood, except those shallow areas and
embayment into small drains and gullies where
water would be ponding but would not be
effectively convey flood waters. In lieu of and
until such standard is in place, FEMA should
consider designating the BFE to that calculated
for the “with floodway” conditions as a minimum
national standard and also encourage states to
adopt such “full conveyance floodway” concept
as a higher standard floodway. [FEMA, with
Experience with an artificially defined standard
for designating a floodway has shown that
unless the entire flow conveyance path is
designated as floodway, negative impacts in
terms of increased flood elevations are resulted
by “permitted fill” in fringe areas. Time has
come to accept the primary floodway corridor
nature uses to conveying flows also as the
“regulatory” floodway.
NFPPR rec and rationale
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guidance and
congress]
assistance
from
TMAC
and
14. Require that for regulatory purposes the mapped
floodway for an area with an accredited levee
include the entire foot print of the levee through
its landward toe and that the regulations should
prohibit all development within the prism of the
levee. [FEMA]
To ensure that development and encroachment
within the prism (foot print) of a levee does not
occur, the regulatory floodway should extend
to landward toe of the levee
15. Delete the rounded, whole-foot elevations from While it is understood that the BFE lines are
the BFE lines (“squiggly lines”) on the FIRM. included to show water flow and assist the user
and may be beneficial, there is no need to
[FEMA]
include the whole-foot BFEs with the BFE lines
now that BFEs to the nearest tenth of a foot are
listed on cross sections on new maps. The
rounded BFEs only serve to confuse the user in
an already complicated process to obtain a BFE
at a property or structure for insurance and
regulatory purposes.
16. Consider Placing expiration date on all Flood
Insurance Studies and Flood Insurance Rate Maps
(and make the non-expiration status of FIRMs in a
community as a condition for the community’s
eligibility for NFIP participation) [FEMA]
The FIRMS are based on existing conditions.
Therefore some assessment should be made as
to how long the FIRM is reasonably accurate for
(likely max of 15 years).
COASTAL
17. Incorporate LiMWAs on all coastal flood maps
and adopt enhanced design standards for
construction of new buildings in these areas.
[FEMA]
Incorporation of LIMWA’s on all coastal flood
maps will alert the regulating agencies of
another unique flood hazard zone that would
require an appropriate specific set of standards
18. Develop a coastal A Zone definition and provide The nature of coastal A zones is very different
from A zones in riverine areas. However,
that definition in the CFR. [FEMA]
currently a separate definition for each of these
zones does not exist.
NFPPR rec and rationale
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NFPPR rec and rationale
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