National Flood Policy—ASFPM 2015 Recommendations
A. Flood Mapping
A.1. Depict failure zones(“protection zones”)
associated with dams, levees, diversions,
reservoirs or other structural projects on maps; at
a minimum, map as A Zones and mandate
regulatory action, flood insurance (Preferred Risk
Rates if warranted) and mitigation within said
failure zones. Use zone D is to depict
“Undetermined hazard” associated with Structural
project only on lands under federal ownership,
such as National Parks. Also see G.1.
Also phrased “A.1. Depict failure zones associated
with dams, levees, diversions, and reservoirs on
maps; where mapped mandate regulatory action,
insurance and mitigation. Include probability of
failure with uncertainty bars. Also see G.1.”
A.1.a Use zone D to depict “Undetermined
hazard” only on lands under federal ownership
such as National Parks. Also see G.1. In other
areas not under federal ownership study and map
the hazard. Do not use Zone D, particularly for
areas “protected” by levees.
Also Phrased “Use zone D to depict
“Undetermined hazard” only on lands under
federal ownership such as National Parks. Also
see G.1. In other areas not under federal
ownership study and map the hazard. Do not use
Zone D, particularly for areas “protected” by
levees If requiring insurance in areas protected by
levees, consider the establishment of some level
of regulation for these other protected areas.”
NFPPR Combined comm rec and comments
Insurance should not be required where regulations are not
required.
Comment: extensive use of Zone D should be eliminated
when possible, rather than expanding its use
PMF (Probable Maximum Flood) is already required to be
mapped for high risk dams by FERC regulations and not
publicly available due to security reasons.
USACE is currently mapping some of these failure zones for
USACE dams. Recommendation of adopting their methods
for applying to other public and private dams.
If there is a mandate for some action within these areas, we
need to ensure that funding can accompany such mandate
so that it doesn’t become a requirement only on paper.
I wouldn’t want to be the PE stamping the “probability of
failure” for a structure.
a. There was some pretty strong comments regarding this
issue that involved mostly Insurance implications. There
were those that were of the opinion that insurance should
not be required where regulations are not required. Others
thought that insurance should be strongly encouraged.
Basically comes down to how the usage of Zone D as a catch
all is a slippery slope
A1-A5: “This is exactly the purpose of the non-regulatory
products: to give information the community can use for
local hazard mitigation/development standards that is not
shown on the FIRM. ASFPM’s position might be that the
non-reg products NOT be necessarily the ones that are
defined in some appendix or listed on the KSS site.
The recommendation from ASFPM might be that non-reg
products should be defined as “whatever the community
needs in order to reduce risk (to all hazards)” – whether that
be dam/levee/diversion/reservoir failure scenarios;
geologic/geomorphic/fluvial/channel migration hazards;
coastal hazards; special hazards; areas of the community
with repeated flood damages/rep loss; etc. I think these first
5 could be consolidated into one recommendation about a
very loose definition of “non-reg” products and then each of
these could be sub-bullets that are specific examples of the
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types of non-reg products some communities may need, but
that FEMA has so far not used.”
A.2. Account for geologic/geomorphic hazards on
flood maps, including fluvial erosion /channel
migration zones. Channel migration zones have key
relevance to endangered and threatened species
habitat requirements, e.g. salmonids, as well as
building safety.
Putting all of the hazards on one traditional “FIRM” map
isn’t practical. We should be presenting data, not maps.
This comment can be included on most of these first
recommendations.
LL—disagree—all hazards that relate to flood risk should be
on the FIRM
A.3. Include all flood hazards (coastal erosion, ,
storm surge) on flood maps,. These should be
based on current medium to high GHC scenarios.
Current estimate of average U.S. residential
structure life is 150 years. Also see L.3
Comment: should this specify a date rather than a number
of years? A yearly update becomes necessary on a long
project
Also phrased “A.3. Include all coastal / riverine
hazards (erosion, coastal erosion, subsidence,
scientific and planned projections of sea level rise,
storm surge, increase in coastal / riverine rainfall /
storm events, watershed changes) on flood maps,
using a 150 years-into-the-future standard (future
conditions mapping).”
Modeling becomes very uncertain out to such a time period.
It can also become confusing with the 100-year flood
standard.
Subsidence and seal level rise are not flood hazards and
should not be ‘mapped’ however, subsidence and sea level
rise should be taken into consideration when determining
There is some concern with the uncertainty with this
standard and that the use of this and the following language
related to residential structures is unrelated to what may
happen in the natural and build environments 150 years
from now.
Kinda hard to recommend a 150 year standard when we had
a whole seminar on the 100 year standard, and determined
keeping it was the best course of action. Partially, but not
entirely true
Honeycutt: Storm surge has been considered in FEMA’s
coastal flood maps for >35 years. I think our concern is that
storm surge is not future--LL The Association should cease
writing references like this (incl. in annual Goals &
Objectives) that suggest it’s somehow missing from FEMA’s
data. Several of us have tried to catch/correct this over the
years, but it continues to pop up. This needs clarification—it
may just be terminology—see below
Hillier: Agree with Honecutt’s comment above. However,
concerned with the absence of storm surge in this
discussion. Edit below addresses both needs. See option
para in red
Honeycutt: See comment on L.3 – 150 years is an arbitrary
NFPPR Combined comm rec and comments
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number, and may be inappropriate more often than not.
Better to call for the use of site-specific hazard data that
correspond to more realistic estimates of the useful lifetime
of a resource or investment.
Honeycutt: We should not prescribe the technical approach
in such a blanket fashion, as the science continues to evolve.
Further, global SLR scenarios are only part of the story; local
SL change (due to subsidence or uplift) can mask or amplify
global signals.
Another issue for mapping these risks is how/when SLC is
considered in the engineering analysis; FEMA, NOAA, and
others are working together on pilots being conducted on
different coasts (Atl vs Pacific) that show there is no onesize-fits-all answer. TMAC will also explore the issue of best
methods in detail; ASFPM’s recommendation should
acknowledge this forthcoming work by experts, and not get
out in front of it.—LL—we should place a marker
See some potential wording around use of useful lifetime
and scenarios that reflect risk tolerance offered for rec L19.
While that rec is specifically about sea-level rise, the
concepts are applicable to other future risks and uncertain
conditions.
Can subsidence and erosion in particular be calculated in a
linear fashion that can be projected in this fashion for 150
years? It would seem that the changes in soils and land uses
over time could create significant shifts in these impacts as
would manmade interventions to stabilize coastal or riverine
areas to stop erosion. Aren’t the current maps based on
storm surge scenarios ?
I'M ALL IN FAVOR OF INCLUDING CLIMATE CHANGE IN
FLOOD- AND COASTAL-HAZARD MAPPING. BUT 150-YEAR
PROJECTIONS ARE WAY OVER-AMBITIOUS. SUCH NUMBERS
WOULD BE UN-FOUNDED SPECULATION. EVEN 50-YEARS
OUT WILL BE DIFFICULT ENOUGH, BUT WORTH TRYING
A.4. Include special hazards in producing FISs and
on FIRMs (subsidence, sea level rise, stream
mitigation zones, ice jams, flash floods, closed lake
basins, debris flow, alluvial fan etc.) where
applicable. Also see M.1, N.1, N.2
Also Phrased “Include special hazards in producing
FISs and on FIRMs (stream mitigation zones, ice
jams, flash floods, closed lake basins, debris flow,
alluvial fan etc.) by either representing a State or
NFPPR Combined comm rec and comments
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local community’s mapping or by creating a
national program performance standard. A
standard protocol can be recognized from existing
state programs who are doing such work. Also see
M.1, N.1, N.2”
A.5. Map areas with repeat flood damage claims
and adjacent areas with repeat flooding histories
in all flood zones (SFHA and outside SFHA) Also see
G.10 LL—some of this info crossed out probably
needs to remain
There are a number of federal Privacy Act issues related to
information specific to properties. Consider repetitive loss
‘areas’ or perhaps creating a localized database of losses
with their associated building condition and attributes (LAG,
finished floor, etc) and with attributes of the flood event
(relative surface water elevation, velocity, etc). Then
Communities can use this information for buildings that
have attributes that indicate probable damage under
particular scenarios.
Consider recording repetitive loss information on the
property appraiser/tax collector data for the property. This
would alert potential buyers of the repetitive loss and they
would also have access to any improvements to mitigate
future losses or at least be aware of needed improvements.
There are a number of federal Privacy Act issues related to
this. Areas are okay; specific properties are not.
Comments/questions offered by Jennifer Gerbasi
(Terrebone, LA):
This would be very helpful for jurisdictions with large forced
drainage systems that have repetitive flooding. At this time,
the floodplain manager must develop a height for elevation
of severe repetitive loss structures or substantially damaged
structures required to elevate outside the SFHA.
I am not sure about the increased cost for claims as that
encourages people to avoid claims (as preferred risk
insureds have told me) and therefore 1) defer repairs or
maintenance, and 2) misrepresent the flood risk to the
structure and area.
Any suggestions regarding “repetitive loss” should carry a
definition that specifies whether these are for new definition
(substantially damaged) or the old definition pre-BW-12 of
two floods with claims over $1,000.
To me, A.5 could be split into mapping and insurance
components. Identifying specific properties as flood-prone
on maps will run into heavy resistance and may be a Privacy
Act violation. On the insurance side, they already have the
capability to implement higher premiums.
Any suggestions regarding “repetitive loss” should carry a
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definition that specifies whether these are for new definition
(substantially damaged) or the old definition pre-BW-12 of
two floods with claims over $1,000.
(Referencing comment above) I thought this “NFIP
definition” of a rep loss property still exists – I think the AW501 uses this definition and not the BW12 definition. BW12 I
think applies only to FMA and the higher federal funding
shares depending on RL/SRL.
A.6. Allow non-regulatory products or other
simplified processes to be used as a better way to
assign flood risk for insurance purposes, either
through separate map or other means, then use
flood maps for regulation/planning/management,
provided that non-regulatory products are clearly
identified to prevent the appearance of multiple
flood risks and to prevent cherry-picking of risks.
From Mark Riebau: Do not waste precious funds on nonregulatory products. There has never been enough money to
do the job right, why waste even a dollar on non-regulatory
products. As the name implies, non-regulatory products
cannot, and are not, used by local government for regulation
and regulation is a key to mitigation.
Non-regulatory products should only be produced with
FEMA mapping dollars where the additional cost in minimal,
as there is often a shortage of flood mapping dollars around
the country.
Comment received: this is a significant change from the
historic use of the Flood Insurance Rate Maps – the use of
the FIRM for FPM was always secondary. This proposal
reverses the uses
This entire comment is backwards. Flood maps and FIS are
the products used for insurance and the full suite of
products
Yes, this needs to be re-written, not sure what the intent
was.
These recommendations seem backwards: all of the above
(A1-5) should be non-reg; THIS is one of only 2 main
purposes of the regulatory products.
From Jennifer Gerbasi:
I do not know what options there might be or why one
might want to divorce the best available data (many would
argue flood maps) with a presumably less scientific
approach.
Hillier: concur with Gerbasi point above. Is this intended for
areas where detailed engineering analysis is not available?
Or to potentially supersede FEMA mapping?
A.7.(a) Fully fund and implement National Flood
NFPPR Combined comm rec and comments
b. FEMA’s terminology for their programs may change (Map
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Mapping Program (NFMP) as directed by Congress
in the 2012 NFIP Reform
Mod, Risk MAP, etc) –this recommendation stands as is
without the addition of “and Risk MAP” at the end.
A.7. (b) Fund map maintenance and regular map
updating as continuation of the National Flood
Mapping Program
A.7. ( c) Capture unmet map needs from the
MapMOD and RISKMAP scoping and discovery
efforts. These unmet mapping needs should be
summarized by state and county and provided to
the Technical Mapping Advisory Council (TMAC).
Does comment in green at left imply that the FEMA data on
unmet needs is adequate? Should there be local/state
input?--LL
A.8. Continue to fund flood mapping &
maintenance outside of NFIP policy and fee budget
to the full authorized BW-12 levels ($400
million/year).
This should be done outside of the NFIP policy and fee
budget to the full authorized BW-12 levels ($400
million/year).
A.9. Utilize and implement the appropriate
recommendations of the 2014 Technical Mapping
Advisory Council; Consider establishing TMAC as a
long-term or permanent council
Consider defining “appropriate” for clarity
Terminology like “new” should probably stay out of a
document meant to live a long time. If you mean the current
iteration, then say “2014” instead? done
Honeycutt: Consistent with comment offered on sea-level
rise mapping recs (A3, L19), we need to make sure ASFPM
does not contradict itself (re: A9) and get out in front of
TMAC on this topic and advocate prescriptive (and
inappropriate) procedures for considered SLR in mapping or
flood risk management. There are some general principles
that are gaining acceptance in the interim, and I recommend
we stick with that.
A.10. Revise the NFIP requirements to require or
provide incentives (e.g. CRS) for communities to
establish GIS layers for ground-surface subsidence,
coastal or riverine erosion, channel migration, etc.
(as part of the 100 year standard)
This is a difficulty where subsidence is variable across an
area and changes at different rates. This responsibility is
best pushed down to and accepted at the local level – good
to have CRS credits for this activity.
Also add to the “non-reg” product types above
Also phrased “Revise the HM / PDM grant
standards to allow for communities to apply for
grant funding to establish GIS layers for
subsidence, channel migration, coastal / riverine
erosion, sea level rise and other risk factors ,as
part of the 100 year standard.”
This is interesting. Maybe this could be interpreted as an
eligible activity under PDM planning grants? Communities
will need funding to develop the research that would
underpin these layers. Maybe this would be eligible for
funding under the Continuing Training Grants for Rural
Planning.
Also phrased “Revise the NFIP requirements to
require or provide incentives (e.g. CRS) for
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communities to establish GIS layers for subsidence
(as part of the 100 year standard), where
subsidence poses a flood hazard.”
Also phrased “Revise the NFIP requirements to
require or provide incentives (e.g. CRS) for
communities to establish GIS layers for
subsidence, coastal or riverine erosion, channel
migration, and other flood hazards as part of the
1% annual chance standard.”
A.11. (a) Produce coastal bathymetric maps and
integrate with coastal topographic maps to
produce maps depicting storm surge, increased
water surface elevations, reach of flooding in
coastal A Zones—Multi agency effort. Also see
L.16
A.11 (a) Develop a coastal A Zone definition and
provide that definition in the CFR.
A.11 (b) Map and change the V-Zone (may only
require FEMA to change mapping std, since the
breaking wave std is there, not CFR) standard from
3’ breaking wave to 1.5 foot waves in 1-percent
chance event as supported by FEMA research and
analysis. Establish a standard to base V-Zones and
Coastal A Zones based on future conditions and
best available science and data; require NFIP
regulations and insurance to reflect this standard.
Increase the use of Coastal A zone mapping
(including LiMWA [Limit of Moderate Wave Action)
on large in-land lakes where appropriate.
A.11 ( c) In communities where FEMA has
identified coastal high hazard areas and LiMWA
has not been identified and mapped, require new
construction and substantial improvement of
structures within 1,000’ of mean low tide, or 500’
landward of areas identified as Zone V, V1-30 and
VE, whichever is the larger area, meet the
requirements of construction within Zone V, V130 and VE.
we have not previously mapped or shown zones over the
water areas; not too many cases where an insurable
structure will be there
a. Hillier: Can A.3 and A.11 be combined in some fashion?
Taking into account the recommendations provided by
Honeycutt.
a. Honeycutt: See comments on L16.
This seems to be yet another rec based on erroneous
assumption by some in ASFPM that FEMA’s current coastal
flood maps don’t consider storm surge – they do, and have
for >30 years. Also, current engineering procedures (G&S)
call for use of bathy and topo data – not sure this rec is
actually calling for anything new/different.
a. Honeycutt: Should be cross-referenced to L16, not L17.
a. We support the availability of Coastal A Zone
determinations from FEMA during the mapping process, but
not necessarily the inclusion of the Coastal A Zone into the V
zone definition. There are different mitigation options
based on the different level of risk, and we would prefer to
keep the flexibility to apply higher standards at the local
level than to have these two different risk levels combined
streamlining the limitations on funding and development
techniques. LL---???
At this time, CRS is offering incentives for regulating the
Coastal A Zone like the V, while the mapping side of the
house refuses to provide the LiMWA. Our parish funded this
effort independently and will move forward with it if the
governing body agrees to adopt it, but FEMA has all the data
and could run it in a more consistent and efficient manner.
(A.21 covers this without ambiguity).
b. If they change the definition of V to 1.5-foot, there will be
no such thing as a coastal A anymore, or a LiMWA (see
comment on A21).
NFPPR Combined comm rec and comments
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b. Leslie Durham: This is already being done under the
projects funded under Risk MAP. Is the comment trying to
suggest mapping the storm surge maps that NOAA creates
for the different categories of hurricanes? This is being done
as well, but not included in the FIRM maps. Perhaps we
should stress data availability?
b. Hillier: Recommend allowance for alternative definitions
of the Coastal High Hazard Area beyond wave height based
definitions.
b. Honeycutt:
This needs to be reviewed/revisited and made harmonious
with the recs about requiring mapping (and/or
management?) of LiMWAs – same concept. See A21 and
L18.
Also, at least one Coastal Cmte member (J. Gerbasi)
preferred leaving the V Zone mapping criteria unchanged,
and instead called for strengthening of coastal A zone
floodplain mgmt. criteria. Her community wants to keep the
flexibility in how they can mitigate risks in coastal A zones,
which would be lost if these areas were remapped as V
zones.
Recommend dealing with this issue as part of an expanded
LiMWA rec – A21 and/or L18.
A.12. (a) Provide FEMA authorization to delegate
authority and funding for mapping of all coastal
and riverine flood and related hazards on NFIP
flood maps to qualified states that request such
authority under the Cooperating Technical
Partners program. Maps produced by CTP states
must be to FEMA mapping standards or higher.
Also phrased “Delegate authority and funding for
mapping of all flood hazards on NFIP flood maps to
qualified states and local partners under the
Cooperating Technical Partners program. Program
should require the authorized states and local
partners to undertake the mapping in accordance
with standards that equal or exceed FEMA’s
standards.”
A.12. (b) 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 Services Center. Encourage
NFPPR Combined comm rec and comments
a. We defined flood hazards as more than just coastal and
riverine in statement above.
a. Careful here, political will within the state may lead to
areas being mapped that do not have top priority to be
mapped (areas with high risk, areas with repeated flooding,
areas with outdated or inaccurate maps may continue to be
overlooked on a routine / regular basis); instead areas will
be mapped that are high population centers simply because
of the political pressure being exuded on the state by the
constituency – see Georgia for examples! That is what FEMA
does when they set priority for mapping. We could have a
rec that priorities for which maps get done are based on ???
State/fed agreement? State with fed input? LL
a. Comment/concern from Jennifer Gerbasi (Terrebone, LA):
Ignoring for the moment the constitutional status of states
v. local or county governments, does this have to be a
FEMA/State delegation? Some local jurisdictions have
better information and different political priorities than the
state and may be better able to achieve optimal goals. Los
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and provide funding incentives all states to archive
flood map data In digital, electronically
transmittable format.
Also phrased “Require states to develop and
maintain an archival system for all flood map
models for data stewardship and storage. “
A.12. (c) As an alternative to the current mapping
program, and for sustainability of the program,
FEMA could focus its attention to completing and
maintaining a fully digital national flood hazard
layer (rather than trying to maintain flood “maps”)
and leave the updating, maintenance, and
stewardship/ management of
topographic/bathymetric data, base maps, political
boundaries, or other data layers of interest to
other federal and state agencies. FEMA should
maintain meaningful links to these other data sets,
possibly utilizing ISBN, doi, etc. Data sets should be
available at least until any references to them
would be for only historical purposes rather than
legal, insurance, purposes, etc. A “map”, suitable
for each purpose (such as flood insurance,
floodplain development management, zoning,
etc.), can then be assembled by each local state or
entity and printed on demand; incentives will be
needed for this to happen
Angeles County is bigger than some states by land and
population, for example. Understanding the value of
developing maps based on watersheds that can cross
jurisdictional boundaries, states are as prone to these
limitations as local communities. I would not always jump
to the state as the smallest level of partnering agency.
a. (Should also require those states that are so authorized to
undertake the mapping in accordance with standards that
equal or exceed FEMA’s standards.) .
a. Ignoring for the moment the constitutional status of
states v. local or county governments, does this have to be a
FEMA/State delegation? Some local jurisdictions have
better information and different political priorities than the
state and may be better able to achieve optimal goals. Los
Angeles County is bigger than some states by land and
population, for example. Understanding the value of
developing maps based on watersheds that can cross
jurisdictional boundaries, states are as prone to these
limitations as local communities. I would not always jump
to the state as the smallest level of partnering agency.
c. Mark Riebau) I cannot support this recommendation so
long as flood insurance is based on the flood maps. This
issue needs lots of discussion.
c. Carlton: I think we should go stronger here, that this is the
model of map production moving forward.
c. This needs some strong discussion – see preceding
comment about political pressures; Also many communities
don’t have digital data of any kind – this thought process is
way ahead of its time
c. Doesn’t this require states to change (or FEMA to change)
to a layer being allowed as a “document” of regulation? Isn’t
a published map the NFIP regulatory and insurance
document?
c. To achieve this type of approach, local capabilities need to
be built to allow for local administrators to be able to use a
fully GIS-based system. Additionally, the viability of this
approach should be fully researched to see what drawbacks
and benefits may result with such an approach.
A.13. Increase use of CTPs for delineating all
coastal and riverine hazards on maps
NFPPR Combined comm rec and comments
Mark Riebau: Except in a very few instances, the use of CTP’s
has been a failure for producing map products—LL some
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have the opposite view
Repeat of A12a?
Honeycutt: Is this duplicative with A12(a)?
From a practicality perspective, there will be few CTPs able
to take on coastal analyses. There are efficiencies of scale
realized in regional (i.e., multi-state) storm surge modeling.
Not suggesting ASFPM stop advocating for increased CTP
role here, but consider whether there's a way to also
encourage cross-CTP collaboration (and funding) to get at
those efficiencies in the engineering process.
And who is going to regulate THESE folks – who is going to
set up the standards for the qualified states – who is going
to make sure they are doing what they are supposed to be
doing – standards would need to be reviewed every 2 years
or so to make sure they are still pertinent – where is the
time, money and personnel going to come from for this? –
see statement below that pro-development states could
“appear” qualified on the surface, while allowing at-risk-forflood development due to political pressure or ineptitude
In order to ensure that such an approach will be successful,
current CTP guidelines and qualifications should be reviewed
and strengthened so that resulting products are of the
highest quality.
A.14. Expand the LOMR Delegation Program to
allow additional to qualified states and state
designated local authorities, with local review/sign
off as needed Also see S.4
Mark Riebau: Need to set up a strict set of guidelines and
standards that would need to be vetted every 2-4 years.
Comment/concern from Jennifer Gerbasi (Terrebone, LA):
The local authority should always need to be in agreement
with the change required (and I believe that the process now
requires this). The local authority will be committed to
enforcing NFIP regulations based on the maps and is
responsible for the health and safety of the community. The
qualifications at the state level would have to include a
working professional floodplain management staff with
working knowledge of the conditions represented in the
LOMR.
And who is going to regulate THESE folks – pro-development
states could “appear” qualified on the surface, while
allowing at-risk-for-flood development – once this happens
it is like trying to close the chicken coop door after the
rooster has spent a considerable amount of time in there!
Concern here seems to assume the current process in FEMA
NFPPR Combined comm rec and comments
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has good QA/QC which it does not. It is a trade off, and yes,
will require guidelines.
The local authority should always need to be in agreement
with the change required (and I believe that the process now
requires this). The local authority will be committed to
enforcing NFIP regulations based on the maps and is
responsible for the health and safety of the community. The
qualifications at the state level would have to include a
working professional floodplain management staff with
working knowledge of the conditions represented in the
LOMR.
Again, to ensure that this approach is successful, strict
standards and guidelines would need to be developed and
implemented so that states and local authority LOMC review
can be a successful program.
A.15. Produce all flood maps in geospatial data
format & allow all such data as a substitute for
traditional paper products ;
This contradicts A.12(c)
A.15.a. require LOMRs to be in the same
geospatial format, including updated databases,
and be incorporated into the digital layer.
FEMA should be incorporating LOMRs into the panels by
simply changing the database. There is no reason for
publishing paper LOMRs any longer.
As far as I know, this is happening now. Ck this?
Recommendation to delete completely.
A.16. Map riverine floodplains to the upstream
source up to 1 square mile of drainage area. Also
see G.2, T.8
In addition we should move towards watershed hydraulic
and hydrological modeling and mapping.
Recommendation to delete completely.
Also phrased “Map floodplains and other flood
hazards of to the upstream source to a specific
minimum watershed size or appropriate minimum
unit for the mapped hazard and expected risk and
development. Also see G.2, T.8”
A 17. Make past flood maps readily available in
digital, electronically-transmittable format.
As a first step, identify known maps not yet
available electronically. However, this initiative
should only be a priority when the National Flood
Mapping Program is fully funded to the
$400M/year level. Leslie Durham comment
The issue of archiving maps and use of best
NFPPR Combined comm rec and comments
Comment from Jennifer Gerbasi (Terrebone, LA):
The use of the old maps needs some attention as well.
Insurance companies have been refusing to use the maps
prior to the first FIRMs though they were the best available
data at the time and relied upon by NFIP communities prior
to the availability of the FIRMs. Flood boundary maps were
the best available data at the time, but are not being
consistently recognized as acceptable to show compliant
building. More structures are therefore found to be minus
rated than if these maps were recognized as a sufficient
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available data where map exists but FEMA has not
issued FIRM (sometimes takes years) needs to be
addressed also
basis for regulatory decision making.
The use of the old maps needs some attention as well.
Insurance companies have been refusing to use the maps
prior to the first FIRMs though they were the best available
data at the time and relied upon by NFIP communities prior
to the availability of the FIRMs. Flood boundary maps were
the best available data at the time, but are not being
consistently recognized as acceptable to show compliant
building. More structures are therefore found to be minus
rated than if these maps were recognized as a sufficient
basis for regulatory decision making.
Should include a statement of purpose – to what end should
historical data be available?
If we continue to agree with the use of the 1% annual
chance flood event as an inundation and velocity zone
standard, the hydrologic record needs to be more frequently
revisited to ensure that the record is including recent flood
events and frequencies for predictive modeling.
A.18. Develop a standard to allow for
determining the ‘best floodway modeling
practices’ in areas where existing standards may
not be suitable. The new standard would allow
for states and communities to evaluate the
options and determine the best floodway
definition for the specific area. This would
require that certain minimum standards would be
maintained, but would allow for addressing nonconforming areas, allowing usage of unsteady
and 2D models and other tools to better depict
the flood hazard.
A 18.(a) Map floodways based on no cumulative
flood rise (zero rise) and no adverse impact on
other properties
Also phrased “) Map floodways based on no
cumulative flood rise (No Rise / Zero Rise) and No
Adverse Impact on adjoining properties. (Should
we somehow reference future conditions mapping
here? Isn’t that what this is talking about in
essence?)” LL—no this is not future conditions, but
rather legal equity so all properties in the FW have
the same right to encroach
NFPPR Combined comm rec and comments
Leslie Durham: Suggest deleting these 4 statements A18a, A18b,
A19 and A 20 and replacing with something similar to the revised
A.18 at the left.
a. Does this apply to LOMCs?
a. WOULD BE INTERESTING TO HEAR WHAT YOU INCLUDE
UNDER "CUMULATIVE FLOOD RISE". PERHAPS TOO MUCH
OF A CAN OF WORMS FOR THIS SHORT POLICY DOCUMENT,
BUT MAYBE 1 ADDITIONAL SENTENCE OF EXPLANATION
b. The entire levee should be mapped as within the
floodway for regulatory purposes, and the regulations
should prohibit all development within the prism of the
levee.
b. We now have an exemption to the current policy in
Indiana.
b. The entire levee should be mapped as within the
floodway for regulatory purposes, and the regulations
should prohibit all development within the prism of the
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A.18. (b) In performing flood studies where an
existing levee is assumed to contain the 1% chance
flood, use the riverward toe of the levee as the
landward edge of the floodway. LL I like the
comment about prohibiting development with the
prism of the levee--LL
levee.
b. AGAIN, I THINK I SEE WHERE YOU'RE GOING WITH THIS –
PROVIDING A CONSERVATIVE AND DATA-DERIVED BASIS
FOR DEFINING AREA PROTECTED BY A LEVEE -- BUT
STATEMENT AS WRITTEN LEAVES IMPORTANT QUESTIONS
UNANSWERED. YOU MEAN THE ELEVATION OF THE LEVEE
CREST, RIGHT? PROJECTED ORTHOGONALLY FROM THE
RIVER? AND NOT AT ALL CLEAR WHAT IS MEANT BY THE
LANDWARD TOE OF THE LEVEE. LL--dealt with above
Comment received: I strongly support this because PM 52
states the floodway should be designated on the landward
toe however private owned property between the riverward
toe and the stream currently falls in a development loophole
with at-risk structures being constructed within the levee
protection area. Communities must face “taking” claims if
they prohibit structures in this area
A.19. Map floodways based upon a combination of
depth and velocity of the water to show the true
hazard and risk to property owners and
communities; include as a standard NFIP flood
map product
Support modern modeling approach using 1D and/or 2D
hydrodynamic models which will support such a products.
A.20. When scientifically justified Map floodways
using unsteady flow models to account for the loss
of storage. Rely on FEMA guidance using this
approach and realize the complexities of affecting
this approach.
A18/19/20 all contradict themselves. Suggest the
development of a white paper on “best floodway modeling
practices”, allow communities to determine the best
floodway definition for their area (with certain minimums).
Also phrased “Map floodways using unsteady flow
models to account for the loss of storage.
Alternatively, if steady flow models are used for
floodway determination, the hydrologic impacts of
lost valley storage, due to encroachments should
be analyzed and floodways adjusted accordingly.”
This will require development of standard flood hydrograph
for river reaches or whole watershed.
Is the expense justified by the outcome? Or should
traditional analytical methods be used the majority of the
time?
This is a very expensive and often unnecessary option. This
should only be done where scientifically justified, and that is
not very often. More important would be to change the
allowable increase to 0.01’ and continue to use traditional
analytical methods.
Due to the high cost of modeling, this level of analysis should
be commensurate with the level of risk. An alternative
method of protecting floodway areas should be developed.
Such an approach could use a more conservative floodway
standard (no fill or structures regardless of rise, accounting
NFPPR Combined comm rec and comments
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National Flood Policy—ASFPM 2015 Recommendations
for no increase in velocities as well as flood heights, etc.) to
account for floodway impacts.
A.21. LiMWAs should not be optional and should
be included on all coastal maps or on large in-land
lakes.
Also phrased “LiMWAs should be depicted on all
coastal flood maps.”
LL—Siavash, all the coastal related issues should
be in one section of A, and riverine in another—if
at all possible
John: Consider including Coastal A Zones (LIMWA)
area in the definition of Coastal High Hazards.
Since the 3 foot wave is not a CFR, it is a mapping
standard. It could be changed to the 1.5 foot wave
or higher without any rule making.
A.22. V-Zones should be mapped on all the Great
Lakes where the modeling shows that conditions
meet V-zone definition requirements, as well as
the special hazard of ice.
Comment received: A minimum setback (500’, 1000’ or
larger) from the V/A Zone boundary should be considered
minimum requirements in areas where LiMWA has not been
mapped
If they implement the 1.5-foot wave V Zone, the LiMWA
wouldn’t be needed
Connection to A11
From 2 committee members (incl. Honeycutt): Question:
What is meant by “used” in the original rec?
If the issue is just that LiMWA should be shown in all
communities, then edits here should be sufficient. (That
said, some have concerns over the appropriateness of this
rec; see comment on L.18.)
If the intent was to require LiMWAs use in floodplain
management and/or insurance, then that needs to be stated
more explicitly. Do we have enough experience with the
LiMWA yet to call for mandatory floodplain mgmt. actions,
or do we continue to leave it optional and a credited activity
under CRS?
Add to the non-reg products list in A1-5 above
Also phrased "V -Zones and LiMWAs should be
mapped on all the Great Lakes where wave
hazards are present, as well as the special hazard
of ice."
A.23. A regulatory flood layer should be provided
to all communities downstream of a dam showing
the flood risk assuming the dam is removed. (i.e.
inundation during the 1% annual chance flood), as
well as the area impacted by a dam failure, where
that information is known.
(b) An (informational) layer should be provided to
all communities downstream of a dam showing
the SFHA assuming the dam fails during the 1%
chance flood.
NFPPR Combined comm rec and comments
Dam breaks do not necessarily produce the SFHA or 1%
annual chance event.
Connection to A21 requirements for “standard flood
hydrograph” and again it will require to move towards
hydrodynamic modeling.
Add to non-reg products list in A1-5
Buss: create zone behind levees that regulates as if the levee
did not exist—to keep risk from increasing
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A.24. Develop a standard for and Produce future
conditions mapping that includes all projections of
sea level rise, increase in riverine rainfall,
watershed changes, due to development and
accounting for watershed development
regulations that are in place.
Some use the future conditions identified in the
community development plan for 20 years in the
future. LL
Consider using 500 year standard in highly
urbanized areas for regs: at least for levees-LB
Add to non-reg products list in A1-5
Delete and Combine with A.3.
From Jennifer Gerbasi (Terrebone, LA):
Combine with A16 to include changes in flooding due to
increased snow melt etc. Considering recent Colorado
flooding, deforestation should be considered as well
whether through disaster or decisions regarding timber
harvest (the new term for clearcutting).
Honeycutt:
Rec needs to be checked for consistency with others on SLR
and future conditions, taking care not to prescribe a specific
method since science is still a work in progress. Here, it’s not
appropriate to suggest “all scientific and planned”
projections be used – we should be advocating use of data
and scenarios appropriate to the lifetime of the investment
and its criticality/risk tolerance. (What is a “planned”
projection, anyway?)
A. 25. Revise and update flood flow calculation
guidance in bulletin 17 B to reflect the
recommendations to the Subcommittee on
Hydrology to produce updated Guidelines for
Determining Flood Flow Frequency titled Bulletin
17 C.
This is happening (reference to Bulletin 17 C).
A,26(a) Require participating communities to
provide updated corporate boundaries within 6months of any annexation or change. (Since that
is already a requirement in the CFR, maybe the
recommendation should be a fine of $1,000/day
for every day the change isn’t reported.)
This is already a requirement in CFR, but is not enforced.
If that is true, modify to say “enforce”
A.26.(b) Encourage FEMA to implement a digital
solution to updating layers and base map
information (such as corporate boundaries, etc)
with a reference a layer that can be routinely
updated.
A.26.(b) Require FEMA to publish a LOMR
displaying the boundary change under (a) within
60 days.
A.27 Establish new flood zones and mapping
standards for areas protected by flood control
NFPPR Combined comm rec and comments
This comes from the National Academies recommendations
for risk-based analysis of levee systems
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structures, relates to I.8.
A.27. Consider the use of better flood risk
communication terms; rather than using “A zone”
and “V zone”, develop a better term to
communicate risk, as well as better terms to
represent the continuation of risk throughout the
floodplain and community.
A.28 Revise protocol to allow for the final
products be map layers, not maps. Layers should
have supporting metadata, domain tables,
profiles, etc. See also A.12.
A.29 Express horizontal accuracy standards in
terms of standard deviation (hyperlink: NIST).
A.31. Let each kind of information be stored in its
own raster.
A. 26. Flood maps or associated non-regulatory
Alternatively, list with A1-5 above
products should communicate risk to the public in
a way the public can understand. For instance,
the maps could convey an area of risk to life
safety during the 1% annual chance flood based
on the areas where flood water depth and flow
could sweep someone off their feet.
A27. An effort should be made to communicate
the risk represented by the return period of a
flood as the areas where a flood is likely within
the anticipated lifetime of a building or mortgage.
Another possible non-reg to add to A1-5 above
A28. FEMA should delete the rounded, wholefoot elevations from the BFE lines (“squiggly
lines”) on the FIRM. While it is understood that
the BFE lines are included to show water flow and
assist the user and may be beneficial, there is no
need to 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.
Jen Marcy: In a related item, and maybe it belongs in the
Insurance Section (G), BFEs listed on ECs are almost always
incorrect in my experience, which includes hundreds and
hundreds of LOMA reviews. It worries me to think of the
incorrectly-rated policies that must be a result of incorrect
BFEs. I don’t know how to fix, either. Perhaps the BFE line
item should be taken off the EC? Or perhaps more training is
needed on how to do BFEs? One thing that will make it
easier is the BFEs to the nearest tenth printed right on the
maps, which FEMA has already done for new maps.
A29. Federal agencies producing hazard and riskNFPPR Combined comm rec and comments
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identifying products to communities, citizens,
insurers, etc., should keep the end-user in mind
when designing such products.
A.26. For MT-1 submittals, require that the
individual signing the Community
Acknowledgement Form (Sections A and/or B) be
a CFM.
A.27. For MT-2 submittals, require that the
individual signing the Certification By Registered
Professional Engineer and/or Land Surveyor
section on the Overview and Concurrence Form
be a CFM.
NFPPR Combined comm rec and comments
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