K. Natural & Beneficial Functions
Leverage existing programs for NBF
K.1. Given the recent farm bill, determine the
viability of conservation easements to protect high
flood risk and high resource and erodible lands in
light in rising crop prices and food demand.
Review the impact of existing programs and
suggest improvements to promote sustainable
uses. K.9 (USDS; FEMA;?)
K.2. (a) Promote the use of existing easement
programs on agricultural or undeveloped lands to
protect areas with high flood risk, highly erodible
soils, loss of floodplain connectivity, and high
resource value for providing ecosystem functions.
This could include conservation easements to
maintain farmland with practices that create
floodplain storage areas during large events.
K.2 (b). Convert Continuous Conservation Reserve
Program to a permanent easement program for
riparian buffers nationwide, or look to establish
riparian habitat banks for projects and areas
where riparian buffers or easements are not
possible. [NRCS,
K.3. Establish a National Riparian Zone Policy. As
part of this policy encourage continuous buffer
zones along all waterways and coasts to preserve
the ecosystem services and reduce flood damages.
Also see C.5, I.14, L. 2, L. 7, C.5 [FEMA; HUD; EPA;
states]
K.4. In all federal policy documents provide
increased emphasis on social and environmental
values, sustainability and resilience and not just
economic development
K.5. MIT-FLG should review Section 404 of the
Clean Water Act to determine how it can
encourage or compliment flood loss reduction
efforts by better protecting riparian areas,
wetlands and waters of the US [MitFLG; USACE;
FEMA; EPA,]
draft 11-20-14
Should include 1) review the impact of existing
programs and then 2) suggest improvements.
A concern is that high crop prices and subsidized
crop insurance has led to the farming of marginal
land.
Build off existing Conservation programs so not
going for new money or authorization
Considerations for easements would include what
type of farm management practices would be
acceptable, how to compensate crop losses given
the public benefit provided through farm field
flood storage.
Term limited easements do not serve the public
interest.
This could be considered as extra points in grant
programs for those communities with a local
requirement because it reduces flood losses and
benefits water quality.
While there may never be a “shift to” but certainly
there should be more emphasis on sustainability.
The impact of any permit application on flood
levels, velocity, erosion or other properties should
always be analyzed and mitigated.
New or expanded approaches
K.6. Establish and fund a permanent
Environmental Restoration Program within the
Corps, not tied to Section 1135, for Corps project
to restore habitat and watersheds throughout the
nation. Projects should have a total construction
cost of not more than $50 million and an annual
budget of not less than $1 Billion.
K.7. Expand the Coastal and Estuarine Land
Conservation Program (NOAA) to include critical
non-coastal riparian habitat. Expand the funding
to recognize the importance of maintaining coastal
and riverine riparian habitat and providing buffers
for climate change.
K.8. (a) States and local communities should
require building setbacks to provide natural
buffers on all streams and coasts to protect water
quality, flood storage, ecosystem services and
development outside of the buffers. [States,
MitFLG]
K.8. (b) Encourage continuous buffer zones along
all waterways and coasts Also see L. 2, L. 7 [FEMA;
HUD; EPA]
K.9. FEMA, communities and states should prohibit
fill in all SFHAs to protect the natural and
beneficial functions of floodplains, including
storage, or determine a way to provide an
incentive to communities that adopt this higher
measure. [FEMA, communities, states]
K.10. Where listed species or their habitat is
present an environmental assessment should be
required for all floodplain permits, or local
standards should meet the requirements of the
relevant biological opinion. [FEMA, states]
K.11. FEMA should map erosion zones and work
with its state and local partners to create
regulations for those erosion zones to protect
development from highly erosive areas including
channel migration zones adjacent to rivers or
streams and erosion areas along coastlines, and
maintain high quality habitat. [FEMA, states,
NGOs]
draft 11-20-14
Yes, it goes beyond 1135, which is only existing
projects. Should be standing authority for
restoration, perhaps with $20 M cap. The Corps is
the agency that does projects so they should be the
ones doing the work. (LA River) Or, should this be
a grant program run out of NOAA?
This is the rare program at the federal level
dedicated to acquiring and preserving land. There
may be other grant programs for endangered
species, etc.
LL—what about LAWCON?
Buffers are one of the most effective means to
protect both water quality and habitat and to
reduce flood damages and flood insurance costs.
Some states have buffers in Shoreland mgt
programs. Often we see grading right to the apex
of the bank and the subsequent failure of the
previously stable bank.
Fed programs can incentivize this in mitigation
grant process by extra points because it reduces
flood losses and protects water quality and habitat
and future disaster costs
Fill is beneficial to the person doing the filling, but
can increase flood risk for others. This
recommendation is a basic NAI concept and it is
credited in CRS.
The application of ESA to the NFIP is being refined
by the courts, and FEMA and National Marine
Fisheries are collaborating on implementation of
appropriate measures where endangered species
exist.
This mapping has been done by State or local
jurisdictions to a standard that should be accepted
by FEMA as the official map. See Vermont model
for mapping
Not only are these areas risky for development,
but frequently provide some of the most valuable
habitat within the watershed
K.12. Increase the CRS minimum points required in
elements that credit natural floodplain functions
for CRS class 4 and 1 communities. [FEMA]
More emphasis on NBF reduces hazards, promotes
many other beneficial functions and services, and
the current requirements are too low to be
effective.
Evaluation of programs and Studies
K.13. Require communities to catalog and annually See Charlotte-Mecklenburg studies that provide a
report the location and amount of all fills within
model of how much impact such fill has on flood
the SFHA to determine the impact on flood storage levels
and ecosystem services and to identify if offsetting
storage has been created. [FEMA; States]
K.14 Require that funding and regulatory decisions
to armor shorelines, stream banks or lakeshores
include an evaluation and assignment of long-term
costs to mitigate the adverse impacts of armoring,
including erosion, scour and habitat as well as the
long term cost of Operation and maintenance. see
also L.4
There is great importance in maintaining and
enhancing NBF and how NBF is a critical part of
overall sustainable flood risk reduction
K.15. Initiate a national study on environmental
degradation that results from water resources
development and the impact of that degradation
on the economy [NSF; MitFLG; NAS]
The intent is to analyze the LOSS of water
resources and riverine/coastal ecosystems that has
occurred over the last century, and what impact
that has on ecosystems, added flooding and
quality of life
K.16. Collaborate to identify ecosystem function in
conjunction with flood mapping and to
integrate/create/enhance those functions in
managing flood risk. [MitFLG; FEMA; EPA, FWS,
NWI, USGS]
For example, groundwater recharge areas may not
show up as a mapped “resource”, but certainly
they provide a function that we’d want mapped
and protected.
See Vermont model for mapping
K. 17. Perform a study to determine the impacts of
floodplain fill since the inception of the NFIP has
had on flood levels and ecosystem services? (There
may be a tie with mapping here if they also want
to propose) [FEMA, NSF; academia]
This would inform how to treat fill in the NFIP or
State FPM programs, and should include examples
of how various states/communities deal with this
issue.
draft 11-20-14
The preference should be to not armor the site
except in extremely rare instances