National Flood Policy—ASFPM 2015 Recommendations
O. Disaster Management & Assistance
O.1. Implement the Emergency Management
Assistance Compact so that it covers key aspects
of the mitigation and recovery phases
It does. I responded to Katrina in Mississippi to
provide support to the SHMO. What limits EMAC
use in longer term recovery is FEMA telling the
states they won’t support EMAC reimbursement
through PA Cat B for more than a few months.
O.2. Restore FEMA to independent agency status
to allow for greater flexibility in achieving their
mission objectives.
O.3. Establish a National Response Plan that
directs federal response but also ensures use of
“discretionary” funds and the goals of long-term
recovery, mitigation and redevelopment
RESPONSE TO WHAT? RESPONSE TO NATURAL
DISASTERS, PRESUMABLY.
O.4. Make the availability of and amount (slidingcost-share)of disaster assistance contingent upon
taking local/state mitigation action
This is tied to the Poverty Index for local
communities. I don’t think this law will change
anytime soon. So rec is to Congress
O.5. Make (disaster assistance) Public Assistance
contingent upon the community and state having
an effective updated hazard mitigation plan and
community participation in any available predisaster mitigation program for which hazards
pose a significant threat in the plan .
Suggest you delete. The state plan requirement
went into effect November 1, 2004. Thus, all states
and territories have approved plans. To expand to
all “communities” is unnecessary and would create
issues for small, under-resourced communities.
We’re seeing this with Tribes right now.
==Revise to state that not just Public Assistance
but ALL Federal agency assistance is contingent…..
and participates in the NFIP
O.6. For natural disasters in flood prone
communities, make disaster assistance contingent
upon NFIP participation, compliance, and
maintenance of insurance for all structures in the
SFHA
Comment received: for all structures in the SFHA
O.7. 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.
That is pretty impossible to dictate. When they
blew the levee in Cairo they knew what it would
do to part of Mississippi but they did it anyway.
Did not hurt properties because already had
easements
O.8. Expand steam gauging network technologies
to flood warning systems.
O.10. Establish a combined review process for
community/state compliance, mitigation,
I think this exists, perhaps change as suggested.
NFPPR Combined comm rec and comments
It pretty much is, certainly for Mitigation and PA.
CONFUSING. COMPLIANCE AND ENFORCEMENT
OF WHAT?
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National Flood Policy—ASFPM 2015 Recommendations
enforcement after a flood
Clarify. As written doesn’t make any sense.
O.11. Establish a comprehensive set of emergency
rules for funding, cost-sharing, and priorities so
federal programs after a disaster are consistent in
flood prone areas
The rules are comprehensive and consistent,
except with policy directives issued by the FCO or
high level feds to deal with specific situations.
Sometimes these policies are tested this way and
then institutionalized for all. I’d delete.
O.12. Establish a uniform set of application forms
for all federal post-disaster assistance for
mitigation
O.13. Work with all federal agencies to ensure
post-disaster policies and programs are consistent
with NFIP and national resilience/sustainability
goals
SEVERAL OF THESE RECOMMENDATIONS OVERLAP
AND WOULD BE MORE EFFECTIVE IF SMOOTHLY
COMBINED 11,12,13?
O.14. Review PA and IAHP and all federal agency
post disaster programs for consistency with all
relevant federal Executive Orders (especially
floodplains, wetlands, resilience and climate
change)
==Make sure that ALL federal programs are
consistent in terms of supporting and reducing
flood risk. Right now, PA and IA are often adverse
to the goals of flood risk reduction of the NFIP
IAHP really has nothing to do with these issues. It’s
repair, temp housing grants. PA goes through a
NEPA review covering NFIP and wetlands, other
EHP. So what is left is resilience and climate
change. Resilience can be addressed somewhat
through PA 406 Mitigation, addressed in H.
Climate change is sort of related where flood
intensity and levels increase. So perhaps modify or
delete.
O.15. Ensure that PA staff and contractors have
expertise to make decisions about post-disaster
reconstruction of public infrastructure and
facilities that incorporate mitigation
Move to Mitigation? Or x-ref
Perhaps this one should require “mit was
considered checkoff on all PWs
O.16. Revise Stafford Act provisions to allow
reimbursement under EMAC? of overwhelmed
communities for post-disaster damage
assessments, substantial damage determination,
ordinance administration, permitting up to 24
months after disaster
O. 17. Collect and share damage assessment
under IA with State and local officials
Who does this? Privacy Act protects Collected
inspection information.
Who will be in charge of seeing that this gets
done?
Totally unnecessary. The inspection is done to
assess eligibility for repair grants and temp
NFPPR Combined comm rec and comments
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National Flood Policy—ASFPM 2015 Recommendations
housing. What is done requiring a building permit
is between the owner and local government,
FEMA permits trailers with the community. So the
inspection data should not be shared, states and
locals don’t need it. They should be enforcing their
own laws and doing their own substantial damage,
public health and nuisance, etc. inspections and
enforcing their laws wow?
O.18. Develop and utilize methods to track all
federal expenditures and lost revenue due to each
disaster declaration in order to determine the full
cost to society and taxpayers of disasters. Publish
preliminary results within one year of the
declaration and final results within 5.
Within 5 ?? What would we do with this
information? Economists and universities have
done lots of studies on multipliers of lost
revenues, business and societal impacts of
disasters. Federal expenditures can be obtained.
Q 19. Establish a federal oversight group similar to
the National Transportation Safety Board, to
collect data and analyze the damages, cause and
economic, social and environmental impacts of all
disasters
Ok, then what? NTSB makes recommendations
pertinent to the transportation industry – what
would this group do? Add what they would do
O.20. Require all federal recovery programs be
reviewed and adjusted to consider mitigation and
resiliency alternatives and evaluate long term
solutions (require that water resource projects and
PL 84-99 for example consider non-structural
measures )
FOR WATER RESOURCE PROJECTS IN GENERAL,
THE NON-STRUCTURAL PREFERENCE IS ALREADY
WRITTEN INTO THE NEW PRINCIPLES AND
REQUIREMENTS-but not implemented
O.21. FEMA, in consultation with other
appropriate federal agencies, develop and
maintain a national comprehensive strategic
framework for mitigation and mitigation related
metrics that are used to measure the success of a
post-event disaster recovery. Require that
mitigation metric be developed by MitFLG and
used as an indicator of a successful disaster
management and recovery
Roy would tell you that its in PPD-8. I think what is
missing are the performance metrics. I’ve been
trying to figure out what those should be since
Hurricane Fran – 1996.
O. 22. Improve the efficiency and delivery of
HMTAP such as allowing FCOs to approve requests
in the field versus FEMA Regions or FEMA HQ.
We could add “within approved guidelines”
Include integration of natural floodplain
ecosystem benefits for long terms resilience
solutions.
O. 24. Assist in Building State Capability in ??
Including Mechanisms to Assist with Catastrophic
NFPPR Combined comm rec and comments
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and Multiple Events.
O. 25. Improve the Federal Government’s Ability to
Supplement State Program’s Capability with
Robust and Timely Technical Assistance in a PostDisaster Environment.
This really doesn’t say anything. The regional feds
show up FAST to state EOPs and get JFOs up in a
couple of days post-declaration. I don’t think this is
necessary.
O. 26. Require detailed tracking and enforcement
of required flood insurance on Group Flood
Insurance Policies and flood insurance on SBA
Disaster Loans post-Flooding. Flood insurance
should also be required on SBA Disaster Loans that
are in NSFHAs.
x-ref to similar in G insurance
O.27. Consider the additional Local Hazard
Mitigation Planning effort of a community-led
post-disaster relocation and recovery planning
prior to flooding or other hazard events.
Consider when and how?
O.28. Support/develop/promote apps or other
crowd-sourcing approaches for immediate
disaster notification or for post-disaster recovery
information dissemination.
NFPPR Combined comm rec and comments
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