National Flood Policy—ASFPM 2015 Recommendations
A. Flood Mapping
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A.1. Depict failure zones associated with dams, levees, diversions, and reservoirs on maps; where
mapped mandate regulatory action, insurance and mitigation. When zone D is used to depict
“Undetermined hazard” associated with Structural project, require flood insurance 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.
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.
A.3. Include all hazards (coastal erosion, subsidence, sea level rise, storm surge) on flood maps, using a
150 years-into-the-future standard. 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 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?
A.4. Include special hazards in producing FISs and on FIRMs (stream mitigation zones, ice jams, flash
floods, closed lake basins, debris flow, alluvial fan etc.) Also see M.1, N.1, N.2
A.5. Map and designate properties with repeat flood damage claims and adjacent areas with repeat
flooding histories (including flooding from stormwater) as floodplain, for regulation and insurance Effort
should be made to identify and map not only specific “repetitive loss” properties, but also other adjacent
areas with documented, repeat-flooding histories, whether or not they technically meet NFIP repetitive
loss or severe repetitive loss definitions. NFIP should institute a surcharge for every claim or so, similar to
auto insurance. Repetitive loss properties can serve as key locations for investigations on “repetitive loss
areas.” Also see G.10
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.
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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.
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 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.
A.7.(a) Fully fund and implement National Flood Mapping Program (NFMP) as directed by Congress in
the 2012 NFIP Reform
A.7. (b) Fund map maintenance and regular map updating as continuation of the National Flood
Mapping Program and Risk Map
A.8. Continue to fund flood mapping & maintenance outside of NFIP policy and fee budget to the full
authorized BW-12 levels ($499 million/year).
A.9. Utilize and implement the appropriate recommendations of the new Technical Mapping Advisory
Council; Consider establishing TMAC as a long-term or permanent council
A.10. Revise the NFIP requirements to require incentives (e.g. CRS) for communities to establish GIS
layers for subsidence , coastal or riverine erosion, channel migration, etc. (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.
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.17 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.
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).
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A.11 (b) Map and change the V-Zone standard from 3’ breaking wave to 1.5 foot waves in 1-percent
chance event as supported by FEMA research and analysis.. Depict 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
A.12. (a) Provide FEMA the authorization to delegate authority and funding for mapping of all coastal
and riverine hazards on NFIP flood maps to qualified states under the Cooperating Technical Partners
program. (Should also require those states that are so authorized to undertake the mapping in
accordance with standards that equal or exceed FEMA’s standards.) .
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.
A.12. (b) Require CTP delegated states to develop and maintain an archival system for all flood map
models for data stewardship and storage. Encourage and incentivize all states to archive flood map
data.
A.12.(cAs 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 data,
base maps, political boundaries, or other data layers of interest to other federal and state agencies. 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
A.13. Increase use of CTPs for delineating all coastal and riverine hazards on maps
A.14. Delegate authority to review LOMRs to qualified states and state designated local authorities,
with local review/sign off as needed Also see S.4 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.
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A.15. Produce all flood maps in geospatial data format & allow all such data as a substitute for
traditional paper products ;
A. 15 (A) require LOMRs to be in the same geospatial format, including updated databases As far as I
know, this is happening now.
EMA should be incorporating LOMRs into the panels by simply changing the databaee. There is no
reason for publishing paper LOMRs any longer.
A.16. Map floodplains to the upstream source Also see G.2, T.8
A 17. Make past flood maps readily available in digital, electronically-transmittable format 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.
A 18.(a) Map floodways based on no cumulative flood rise (zero rise) and no adverse impact on other
properties
A.18. (b) In preforming flood studies where the levee is assumed to contain the 1% chance flood, use the
or landward toe of the levee as the landward edge of the floodway.
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
A.20. Map floodways using unsteady flow models to account for the loss of storage
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.
A.21. LiMWAs should not be optional and should be used on all coastal maps.
A.22. V-Zones should be mapped on all the Great Lakes, as well as the special hazard of ice.
A.23. a. An [informational] layer should be provided to all communities downstream of a dam showing
the SFHA assuming the dam is removed.
A.23(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.
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A.24. Produce future conditions mapping that includes all scientific and planned projections of sea level
rise, increase in riverine rainfall, watershed changes, etc. 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).
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.
A,26(a) Required participating communities to provide update corporate boundaries within 6-months 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.)
A.26.(b) Require FEMA to publish a LOMR displaying the boundary change under (a) within 60 days.
B. Hydrology & Hydraulics
B.1. (a) Account for flood depths and velocities in setting zones and insurance rates; new charts or tools
should be provided to insurance agents to streamline rate selection, relates to A.19
B.1. (b) Provide flood depth grids as part of the FEMA flood map series and require communities to
adopt those maps for administering the NFIP requirements in their community
B.2. Automate data inputs and update regression equations using updated geospatial land cover and
gage data.
B.3. Use Doppler rainfall data more effectively in flood flow predictions
B.4. (a) Incorporate future-conditions hydrology and cumulative impacts into flood risk determinations
under the NFIP Flood insurance studies should identify assumptions for hydrologic estimates, especially
for future conditions; adjust planning and regulation to avoid transferring the responsibility from those
that cause the problem to those that suffer the consequences.
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B.4.(b) Ensure that the cumulative impacts of encroachments be incorporated into all flood risk
determinations such that there is no resulting increase in flood elevations without associated mitigation
actions
This needs to include specifics such as:
1) purchasing flowage easements
2) buying flood insurance for affected properties
3) purchasing and relocating affected buildings
B.5. Fund and issue updates of National Weather Service regional rainfall frequency curves
B.6. (a) Develop engineering models that are properly calibrated to historic flood events to reduce the
uncertainty associated with the model results before such models can be deemed validated. .
B.6. (b) FEMA needs to establish guidelines and quality assurance protocols for evaluating the unsteady
and two-dimensional models, reporting requirements appropriate for these modeling techniques, and
for the development and review of floodway boundaries derived from such models.
B.7. Ensure that engineering models are open source, public, user-friendly, and widely accepted
B.8. Calculations of flood flow frequencies should be determined based upon a 95% confidence level to
reduce the uncertainty in associated flows used for flood risk determinations.
B.9 Use the 1% chance flood plus future conditions and freeboard for mapping and regulation
C. Stormwater Management
C.1. Emphasize integration of water quality and quantity (flood loss reduction) programs and foster
holistic and no adverse impact stormwater approaches at state and local levels
C.2. Consider both flooding and water quality in all FEMA HMGP and Environmental Protection Agency
Section 319 demonstration projects
C.3. Require critical facilities to consider and quantify both mapped flood risk, but also the potential for
increased risk due to land use changes and climate change by quantifying watershed and stormwater
runoff that affects the site. Don’t we already look at pre and post stormwater runoff as a practice for all
permitted activities in the floodplain? Is this to assess risk outside the floodplain? Including climate
change here if it is not already folded into the mapping process seems wise. The rest would seem to be
in place.
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C.4. Encourage/incentivize (CRS and other) rainfall and runoff infiltration, low impact development and
green infrastructure techniques to reduce and manage flood flows and runoff, water quantity and water
quality. I would like to see more explicit focus on infiltration and permeable surfaces rather than a focus
on moving water away from the land via conveyance. Good direction that already has some traction.
C.5 Apply and expand NFIP Community Rating concept to allow EPA and FEMA to credit community
actions to reduce stormwater flooding risk and to improve water quality and green infrastructure.
Credits could come in form of advantageous sliding cost-shares for grants, disaster assistance, or other
incentives.
C.6. Encourage or require watershed management that prevents an increase in flood flows by new
development via control of not only peak flows, but also the volume of runoff. Already incentives in
CRS. (look up prior to submission )
C.7. Wetlands and other storage areas outside of the SFHA should be preserved to prevent downstream
increases in flood frequency and heights. This is the type of activity that could be awarded CRS points in
multijurisdictional plans. Recognizing the interdependence of the jurisdictions and protecting the assets
of the upstream community for the benefit of the downstream. This will also outline the potential
liability for changes that might damage downstream investments or assets.
C.8. EPA, as part of MS4 permits should require the control of the peak and volume of runoff to the 1%
event, or greater, to prevent the erosion of stream channels, pollution, and damage to adjoining
structures which creates more pollution. Is there data that suggests that the recurrence of 25 year
storms is such that it should be the design minimum rather than 2 or 10? Should the standard be
different based on the rainfall history and projections for the geographical area?
C.9. Consider requiring building setbacks/buffers from all streams and coasts with that area preserved in
their natural state to reduce flood and ecosystem damages and preserve water quality. Streams should
have a required setback regardless of the area adjacent being natural or not. The stream is a natural
environment and the riparian habitat and environmental services should not be disturbed or eliminated
for the benefit of the adjacent activity. Often we see grading right to the apex of the bank and the
subsequent failure of the previously stable bank.
C.10. EPA guidelines for watershed management plans should include the impacts of flooding and the
impacts of development and the hydrologic regime and flood risk.
C.11. As a prerequisite for Class 4 CRS communities must require all new development and
redevelopment to fully use LID techniques to mitigate their impact. There may be some thoughtful and
valuable disagreement about the value of certain LID techniques and their value to habitat or flood risk,
energy use, land use, etc., so I don’t know that I would feel comfortable supporting this suggestion.
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D. Water Quality
See C. Stormwater Management
E. Data & Technology
1. From Mitigation Committee Respondant: I suggest that the “Open Source”
should not be a requirement to hydraulic/hydrologic models used
for flooding studies since it does not necessarily add value to
the performance of flooding studies.
2. Presently, none of the most used models are open source and that
does not diminish its capabilities for accurate flood
simulations. For Instance, HEC-RAS is not open source The Corps
distribution policy indicates: that “USACE does not distribute
the code Computer Source Code: CEIWR-HEC generally discourages
the distribution of CEIWR-HEC source code. The source code is
usually only required when porting a program to a different
computer or to modify it. If appropriate and available, CEWIR-HEC
will provide the source for these purposes. However, CEIWR-HEC
cannot provide assistance with the code. Source code for
components under development will not be distributed. During
development, some routines will be changing frequently. The
proliferation of code, that is rapidly becoming out-of-date, is
not in the public interest. CEIWR-HEC will make the determination
of when the source code is sufficiently stable on a case-by-case
basis.”
http://www.hec.usace.army.mil/software/distribution_policy.aspx)
3. In my opinion, restricting flood modeling to public models would
hamper innovation and fair competition that helps to improve
software tools. The best 2D models available are not in the
public domain. Many private software developers worldwide invest
enormous efforts and money to produce state-of-the art models. As
an analogy, most software using in the generation of maps
including Operating Systems, CAD, GIS and other systems that are
not open source. Nonetheless they offer quality tools for
Floodplain Managers. Selecting the most appropriate software for
each task should be left to the experts, provided that the
software passes adequate testing procedures.
4. ASFPM should promote the establishment of standardized test that
any model should pass in order to be used for flooding studies.
Other developed countries have made significant advances in this
direction. For instance the UK Environmental Agency has prepared
2D model benchmark tests that allow evaluation which hydraulic
modelling packages are suitable for which types of flood risk
management modelling applications. In thie way government
agencies and consultants can apply available flood modelling
tools with confidence. It also promotes continuous improvement in
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the flood model developer community and has helped to raise
modelling capabilities and standards.
5. FEMA announced last year at the FMA conference in Anaheim that
the Agency was going to eliminate the list of Approved models or
“Numerical Models Meeting the Minimum Requirement of NFIP” and
give more flexibility to choose newer and more advanced models.
The idea was to give the responsibility to the local or national
agency doing a flood analysis to verify the models used to
evaluate the flood hazard adhere to 44 CFR 65.6 a(6). ASFPM
should encourage this effort so that it becomes stablished.
E.1. Provide reliable funds for stream gauging and identify additional funding sources for streamflow
data gathering and analysis. Establish an intergovernmental commission for recommendations to meet
these goals. With increasing evidence of changes in climate and rainfall patterns, the enhancement and
strengthening of the nation’s stream gaging network and stream flow data collection is becoming critical
for flood risk management and long-range emergency and watershed planning and standard setting.
Also phrased: “Provide funds for streamgaging. Fully fund the NSIP and provide frequent updates of
stated regression equations.”
Also phrased: “Provide federal and over funds for stream gauges.” In the interim, OEP managers should
be partners with the floodplain managers as they may have access to stream gage funding that is from
many sources.
E.2. Fund and update and maintain list of critical index stream gauges (NSIP) nationwide—federal
funding of this network is essential.
E.3. Develop mechanisms by which NWS/local warning systems can supplement stream gage data
Comment: the claim of “privacy” of much NFIP individual and geographic area data and the consequent
continual state of public confusion over costs and trends for 45 years has substantially retarded
necessary research and analysis to assist the improvement of many aspects of the NFIP and disaster
program. A major policy shift is needed in this area.
There has been a shift in some states to greater availability of this data to jurisdictions and by extension
their agents for better research and planning. Considering the push to move NFIP to community-based
and private institution provision, the availability of this data could be decreasing, not increasing, if we
don’t push for reporting of all flood activity to the NFIP regardless of the point of sale and claims
payment. Data collected by the Parish through observation (not collection of data for a federally funded
grant application) or submission for permits is arguably already in the public domain, and should remain
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so. I do not know if the fight to make flood data available to the public will increase our access to data
significantly.
This would violate the Privacy Act. Rather than asking FEMA to violate a federal law we should seek the exemption
of this data from the Privacy Act, but that is highly unlikely.
State NFIP Coordinators and SHMOs have access to this information and can release jurisdiction-specific data to
local governments withholding owner name and ss#. Proactive states and local governments use the information.
Otherwise, the “public” isn’t going to understand it, use it, or benefit from it. I suggest deleting from Section E. D.
Mills.
E.5. Develop open-source tools for post-flood damage estimation. This may belong in Section H because
it directly relates to HMGP Policy memos as well as data development specific to the BCA modules. The
rest of E is mostly flood hazard mapping/assessment related.
E.6. (a)Collect nationwide data on number of floodprone structures, dams & levees, population at risk.
New law (BW-12) requires such data as well as other critical data to be both collected and incorporated
by FEMA into future flood insurance rate maps. TMAC can suggest means of collecting and incorporating
data, however, FEMA is required to carry out these requirements. Also see I.11
E.6. (b) The federal interagency group Mit FLG, in consultation with state and local partners should
discuss a continuing process and key roles in how to collect, aggregate, analyze and operationalize the
collection and use of such data in the NFIP, flood damage reduction, disaster assistance, and other
federal construction, development, planning, funding and technical assistance programs.
E.6.(c) Nationwide LiDAR is needed for the entire nation with flood mapping being one of the major uses
of that topographic data since updated, accurate topo data is needed with adequate modeling in order
to produce accurate flood maps. Funding sources can be a combination of different federal sources,
along with state and local sources in order to reduce duplication of effort
E.7. (a) Generate complete list of number and location of residual risk floodplain buildings and
infrastructure and levee-protected buildings and infrastructure nationwide by making community
participation in NFIP, CRS, disaster assistance, HMGP grants, approval of local hazard mitigation plans,
and the Corps of Engineers’ Rehabilitation and Inspection program, (P.L. 84-99) contingent on
community’s supplying and periodically updating that information
E. 7. (b) Collection of the data on residual risk structures and infrastructure could be eligible for cost
share funding from HUD, FEMA and other funding sources.
E.8. Establish nationwide database on disaster costs and the benefit/cost ratios of mitigation, organized
by stream reach or shoreline as designated by the National Hydrography Dataset or State or Regional
equivalent thereof. Track relative disaster costs and responsibilities by levels of government and sectors.
This data is needed because Federal costs for disasters are skyrocketing on a path which rivals the long-
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term unbudgeted imbalance in the U.S. social security system – potentially in trillions of dollars; average
federal share has risen recent decades from modest percentages to 70 percent in recent major disasters.
Data needed to better document costs, trends and values of mitigation. See Q 19
E.9. Determine the true cost of disasters by developing a mechanism to account for all the direct and
indirect costs of a flood disaster. Increasingly, it appears these cost may be 10 times greater than
current estimates.
F. Development Standards, Regulations and Codes
One major challenge that is not included here, and may not be known to some partners, are the
limitations put on mitigation by some communities. Just as some communities don’t allow clothes
drying outside or solar panels (placing unnecessary demand on the electric system) there are other
communities that are trying to protect the existing investments by capping the height that new
structures can be raised or built. Flood insurance should not be discounted in neighborhoods or
jurisdictions that have these restrictions that limit freeboard or even elevations that meet new flood
maps.
F.1. (a) FEMA should work with state and local floodplain managers partners to achieve
comprehensive revisions to NFIP regulations (e.g.. freeboard, no-rise floodway, redefine coastal A
zones, elevation certificates for all; critical facilities protection; substantial damage; better storm surge
information for coastal A Zones) recognizing and taking into account adaptation requirements for
climate change and sea-level rise, and seeking public and stakeholder comments.
F.1. (b) Promote NAI based development standards in the base International Construction Codes (ICC)
codes as well as the ICC green codes As a jurisdiction trying to reduce risk daily, I am prone to
dislike the top down requirements that are broad and don’t give us the opportunity to choose
the tactics that are achievable in our communities. We are working on adopting stricter
standards and are always seeking better information. There is already a set of basic
requirements. If the goal is to push the availability of other lood insurance carriers, this may or
may not move that forward as communities push back against their floodplain managers and
look for other options. Our residents have already proposed that the jurisdiction 1316 at least
the V zone and let people take their chances if they want. The lure of savings is not sufficient to
keep the program active when the increases in premiums constantly exceed the savings gained.
Therefore, the program needs to remain accessible for entry and retain a balance between the
carrot of lower insurance rates and the stick of no insurance at all.
F.1.(c) Require participating states and their communities to adopt the IRC and IRC without exception or
change. (In several states the provisions for determining substantial damage/substantial improvements
has been omitted. This has resulted in 1-story, 2-bed cabins in the V-zone being converted to multistory, $multi-million homes at-grade.)
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F.2. Evaluate CRS activities to determine which ones should be made minimum requirements under the
NFIP regulations: This could be billed as an immediate step toward F.1
F.3. Require mitigation measures (elevation, zoning, insurance) in failure zones associated with dams,
levees, diversions, and reservoirs to reduce residual risk and taxpayer costs . Require, or provide either
incentives or less coverage in these areas?
F.4. Revise NFIP regulations to require 2 or more- feet of freeboard above BFE for new construction in
riverine areas and 3-4 feet of freeboard in coastal areas These should be supported with studies, and
ASFPM should work with the national realtors and appraisal associations to ensure that there is
monetized value in the freeboard element of safety. At this point, our builders have pointed out (which
has been borne out in the appraisals that we see) that neither flood risk, damage, or safety are taken
into account when a structure has been repaired. These should be represented as a value or demerit,
which would further encourage safe building.
F.4.b Require the use of the 95% confidence level for all mapping and regulations of SFHAs, and for level
of protection calculations for all flood control structures
F.4.c Require the use of the medium credible projection of sea level rise by 2100 for all mapping and
regulation (also for the expenditure of any and all federal funds, construction and technical assistance.
F.5. (a) Revise NFIP regulations to require a no rise, no adverse impact on other properties floodway
(apply this no-rise to LOMCs and LOMRs also) No development would be allowed to create a rise
without compensating those impacted. (See F.7, F.8 and F.9) make clear that this policy is based
squarely on fairness to other land owners, land users and occupants, and on public safety and protection
and maintenance of important and valuable floodplain functions.
F.5. (b) No habitable structures should be allowed in the floodway
F.6. Revise the NFIP regulations to define critical facilities, prohibit them in regulated floodplain unless
no alternative exists and they are elevated to above 500-year level with freeboard and estimated future
conditions incorporated, require 500-year protection with access and operability during the 500 year
event, and set other standards as needed Also see J.1–7 I am not sure where this is coming from exactly.
We need to have fire stations near the coast to meet regulations for being within a certain timeframe
from structures. It is infeasible to have the trucks lifted, but we are lucky that we are rarely if ever
subject to flash floods (the vehicles are removed prior to storms). We seek to elevate the offices and
living quarters. I think that at least as much attention should be given to wet floodproofing as always
falling back to freeboard. Local governments, given access to information about the performance of
similar facilities should be able to decide what level of safety is on balance the best for the community.
If, as already happens with PA assistance, the jurisdiction is considered underinsured, maybe the parish
wouldn’t get the same insurance payment. Maybe the fire department doesn’t need to work from that
facility during or immediately after the storm. One solution does not fit all.
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F.7. Rewrite or issue guidance to simplify and standardize compliance with 44 CFR 60.3(c)(10), which
requires consideration of cumulative impacts on flood elevations to ensure the cumulative impacts of
encroachments into the mapped SFHA cause no increase in any frequency flood elevations, velocities,
erosion or other adverse impacts unless all impacts are agreed to by all impacted property owners
through mitigation actions or purchase of easements. This process should allow use of verified nonpublished BFEs.
F.8. Revise the NFIP regulations to require initial floodplain mapping that matches topography for all
USGS blue line streams in subdivisions and large scale developments, and that the map be based on a
hydraulic model that includes a floodway analysis or other approved cumulative impact of
encroachments analysis
F.9. (a) Revise the NFIP regulations to lower the threshold of “large” developments required to submit
100-year flood data (and recommended floodway analyses) Explore alignment of thresholds with
requirements of the CWA. The threshold should be two or more structures and 1 acre or more.
F.9. (b) Require that all new subdivision lots created have enough natural buildable ground above the
BFE to contain the entire building envelope during platting. So, subdivisions in the SFHA need to already
be at the BFE? My house, right now, is only above the new DFIRM due to the slab and 6 inches step up
into the house. This type of regulations is going to put significant pressure on the FEMA mapping effort
or by communities to find or provide LOMRs for land that can be built on. Again, our residents are
already accusing the jurisdiction of angling to not allow building in the coastal areas. To also not allow
building in what is our higher ground, but not above the BFE, would further the appearance that this is
indeed our agenda.
F.9.(c ) Require that when a community has adopted subdivision regulations, that the regulations be
revised to contain required platting and development standards if not already required by a state.
F.9. (d) Require improved stormwater management standards for all new subdivisions that address
lower frequency events (50 or 100-yr events vs. 2- 5-year events). Is there a middle ground here for a 25
year event? As importantly, is there data in the ASFPM intellectual bank to show what the cost
differential for builders is between different storms? My jurisdiction already requires a 25 year storm
for the model, but the general public (who lives in subdivisions that flood despite the regulations)
wanted to see 50 or 100 years as the design model. The building community came out against the
measure demanding that we provide the cost of the additional expenditures, and a benefit cost analysis
supporting the adoption of such efforts. We did not, and do not have, that information, and the elected
officials are not looking like they will move forward without the answers to those questions.
F.9. (e) F.25. Require that all newly platted subdivisions clearly identify all known flood hazards and
related natural hazards (e.g. subsidence, erosion, dam or levee failure, sink holes, etc).
F.10 (a)Develop and implement effective monitoring, probation and suspension guidance and standards
for better NFIP compliance for all NFIP participating communities.
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F.10 (b) For all new structures,the community must be allowed to inspect properties at will to ensure
compliance, and especially at any transfer of the property.
F.11. Revise the NFIP regulations to include identification and management measures for subsidence
related to flood risk management. Also see N.2
F.12. Revise NFIP regulations to prohibit unmitigated fill anywhere in the SFHA, or at a minimum revise
NFIP regulations to prohibit fill for elevation in coastal A zones See F.13 Again, big supporter of the
Coastal A Zone, working on getting that adopted. This is another situation where some local studies or
benchmarks on the cost of elevation with or without fill would be great. There are some great national
academy studies, but those are not accepted by the industry as applicable.
F.13. Revise NFIP regulations to prohibit septic systems in A or V zones Is this an attempt to get
infrastructure extended into the V zone? Coastal communities already have water in the coastal areas.
Sewerage could be next if a significant loss of buildable land is the point o the proposal.
F.14.(a) Revise the NFIP regulations to prohibit or heavily restrict the use of fill for triggering Letters of
Map Change and changes in flood insurance rating. (duplicate)F.15. Revise the NFIP regulations to
require local ordinance to require local floodplain administrator to define they are responsible to
determine substantial damage. Not against this in principle, and this is the practice in our jurisdiction,
but is this practical for all communities? The assessor and permits office often has the data needed to
make this determination. Many floodplain managers are also engineers, building officials, mitigation
officers, etc. This may be an area for a required outreach or education regarding the office required to
make the determination. The guidance could favor education on this topic as it does other topics in the
300 series.
F.14(b) The use of fill should be considered an acceptable elevation technique, but not justification for a
LOMR. In almost every case the property is still within the SFHA and subject to flooding. Moreover, if a
LOMR-F is issued, the property owner can purchase flood insurance at the ‘preferred risk’ rate.
Standards need to be developed before fill can be considered to be outside of the SFHA. For example:





3’ (or more) above BFE
2’ (or more) above 500-year
Contiguous to lands outside of the SFHA (so FEMA quits approving islands in the middle of the
floodplain)
Adequate protection against erosion
etc.
F.15. Revise the NFIP regulations to require local ordinance to require local floodplain administrator or
building official to define they are responsible to determine substantial damage.
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F.16. Revise the NFIP regulations to require cumulative substantial improvement over the life of the
structure . see R.8
F.17. Revise the NFIP regulations to require buildings in coastal A Zones to be designed and constructed
to V zone standards to be more resistant to coastal flood forces
F.18: Evaluate CRS program to recognize more mitigation actions as eligible activities and to increase
points for activities that result in the greatest mitigation benefits. Amen. This message needs to be
adopted by FEMA as well.
F.18 Revise the NFIP regulations to map and regulate an erosion zone with rolling building setbacks and
require all communities to adopt that. 44 CFR 60.1(b). The regulatory standard should incorporate likely
future conditions and reflect the expected useful life of building constructed or substantially improved.
I support buffer zones around streams and any waterway that feeds into a stream or other waterbody.
If this is similar, I am supportive as long as this is sensitive to both the amount of land available and the
creative practices that can stabilize shorelines and provide habitat and storm protection.
F.19 Revise the LOMC requirements to require an Environmental Assessment in all instances to ensure
endangered species are not impacted. I disagree – this recommendation should be deleted in its
entirety. It may be appropriate for LOMR-Fs, but no other LOMR, and certainly not for LOMAs.
F. 20 Establish NFIP regulations to ensure Endangered Species Act (ESA) compliance with development,
LOMR-Fs and addresse other structures with impacts on threatened and endangered species and critical
habitat.
F.21. Promote NAI based development standards in the international green construction code.
F.22. Require V Zone construction standards in coastal A Zones. Flexibility is required in this instance as
well. Our Coastal A Zone has some areas that would need lifts four feet or less above ground. In areas
with low wave action these are allowed to be built on a chain wall, which is an improvement on slabs or
fill, and the right direction without being overly proscriptive.
G. Flood Insurance
G.1. Require flood insurance in 100- and 500- year floodplains, storm surge zones, erosion zones, and
residual risk zones associated with structural projects (preferred risk rates for latter)
G.2. Discontinue practice of waiving the flood insurance requirement after issuance of LOMRs and ,
LOMR-Fs ; apply risk-based rates F.5, K.15, T.8
G.3. Ensure the movement to actuarial rates over time continues for non-primary residences as per BW12 –
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G.4. Gradually eliminate grandfathered rates over time by having a surcharge of x percentage after each
claim of more than some percent of value or by charging actuarial rates once a damage claim is paid
G.5. Movement of insurance rates toward actuarial must be balanced with increased tools, assistance
and funding for mitigation to help homeowners and small businesses with affordability of insurance.
This could include means tested vouchers, credit for mitigation or others means, but must be done
carefully to ensure it does not increase the moral hazard.
G.6. Create more stratification in insurance rates to reflect the variety in risk within flood zones; this
must be linked to providing tools to insurance agents to simply how they can correctly rate a policy. The
current NFIP approach that results in rates for some shallow flooded structure to be the same is deeper
flooded structures does not encourage mitigation or development in lower risk areas.
FEMA can’t even map all the floodplains or update maps that were created 40 years ago. And, the
insurance industry is already doing a lousy job of even making sure the policy is associated with the
correct CID. Making the maps more complicated will do more harm than good.
G.7. Apply mandatory purchase requirement to non-federally regulated mortgages or require that le
Just do away with IA. If you don’t have flood insurance, and you get flooded, your screwed. After almost
50 years it’s time to shut off the money spicket. nder to pay the claim
G.8. Ensure compliance with NFIP mandatory purchase requirements; at every-year anniversary of
mortgage, and upon transfer; ensure penalties are applied for violations.
G.9. Revise NFIP regulations to make zone changes effective immediately, without regard to lender
notification or changes in status of mortgage
G.10. Map any structure outside the SFHA for which two or more damage claims are paid as a
floodplain structure so that insurance is required and regulations apply; also increase the rates 20% with
each claim Also see A.5 For structures (residential or non-residential) disaster assistance should only be
available once. If the building is flooded a second time, and it isn’t insured, too bad.
G.12. Promulgate insurance rules to financially neutralize repetitive loss properties through actuarial
rates, deductibles, or by actuarial rates if mitigation is not done after any offer; incentives can be a part
of this effort
G.13. Set up a procedure by which the NFIP compliance of a structure is automatically verified after a
claim is paid for substantial damage or even a second or third claim, this should be used for eligibility in
CRS and NFIP? (CAV)
G.14. Continually Evaluate CRS to ensure that activities that merit rate reductions are reducing losses
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G.15. (a) Establish clear and rigorous audit procedures for CRS communities compliance, and do this on
a set schedule, especially post-disaster, but also for auditing on a regular basis. CRS compliance is
essential and must carry penalties for non-compliance. All policyholders pay for CRS credits whether in C
And, where FEMA undermines CRS communities by approving inappropriate LOMRs, assess penalties
against the FEMA staff.RS community or not, at a cost of over $200 million per year.
G.15 (b). Require EC’s for all new floodplain permits and require that the community keep copies.
G.15 (c). Examine potential for community based insurance, multi-year policies purchased by and for the
community at-large and based on actual risk. This sounds great, but is fraught with the practical
realization that political influence that would lead to failure.
G.15 (d). FEMA disaster program could offer or work with the reinsurance industry to offer communities
insurance for their infrastructure and disaster assistance in general. It should be required of all
communities and could be subject to the CRS discount. It would cover roads, bridges, waterlines, sewer,
stormwater, power, telecommunication, treatment plants, debris removal, - basically everything now
covered by PA. The only way to reduce PA is direct new development and substantial improvements to
areas outside the SFHA. PA and IA are the “gifts” that keeps on giving for pols.
G.16. Continue marketing campaigns for both purchase and renewal of flood insurance policies; target
marketing to homeowners without mortgages
G.17. FEMA should significantly expand the agent training provided by NFIP Training Contractor, both
the number of courses and topics (i.e., legislation changes, ICC, mitigation options, non-reg products like
depth grids, Changes Since Last FIRM. This should also support agent training that incorporate floodplain
management, flood mapping familiarity , and mitigation, and to require continuing education for license
renewal by end of 2015
G.18. Use outreach, monitoring, and other measures to enforce the NFIP requirement to identify and
insure state- owned and locally-owned floodprone structures, with required pay back to the federal
treasury and NFIP for non-compliance
G.19. Improve working relationship among floodplain managers and insurance industry, with FEMA and
the professional organizations assisting in fostering this relationship
G.20 Modify the NFIP to require mapping and management of and to provide erosion/mudslide
coverage only where those hazards are mapped and appropriately regulated, possibly via a surcharge
G. 21 Establish additional levels of risk zones, or add a surcharge for flood insurance for floodways
(analogous to V Zone ratings) for maps and flood insurance
G.22 Establish higher rates for structures in high velocity or erosion prone riverine areas.
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G.23 (a) Review the existing policy base, and continually perform Quality Assurance, to ensure structures
are shown to be within the appropriate community to prevent policy holders from receiving an
inappropriate CRS discount.
G.23(b) FEMA must issue LOMRs to reflect community boundary changes due to annexations within 60
days of receipt of revised corporate limits.
G.24. Establish a requirement that by 2020 all owners of insured structures must obtain Elevation
Certificates and place on file with local governments and with FEMA. FEMA, working with local
governments, provides incentives to implement. Provide CRS credits for communities who do this for all
floodprone structures; also allow use of other cost share funding for this
G.25. Ensure actual cost of flood insurance is communicated clearly and directly to all policy holders
each year, regardless of discounts or subsidies
G.26. Require signoff of all claims over 25% or similar threshold by community floodplain administrator
as part of claims processing for substantial damage determination and mitigation
G.27. Allow communities direct access to claims data as they are being processed for use in regulatory
processes
H. Mitigation
H.1. Encourage states and communities through incentives to develop holistic mitigation plans that will
contribute to community resilience and sustainability of their economy while integrating multiple
federal programs with a comprehensive review process
H.2. Expand ICC to allow assignment of claim to fully cover the acquisition costs of severely damaged
and destroyed buildings as a means of compliance.
H.3. Increase maximum of ICC coverage to $50,000 with an inflation factor and adjust policy fee as
necessary for costs; allow ICC claims over $50,000 by creating a sliding scale for necessary geographies
to reflect market mitigation costs that requires match funding or other mechanisms that ensure cost
control.
H.4. Establish permanent authorization for US Army Corps of Engineers to conduct nonstructural
floodproofing projects; increase funding for existing Corps nonstructural programs .
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H.5.Streamline and institutionalize methods for delivering mitigation assistance and funding after flood
disasters through development of a mitigation options tool which can be delivered to impacted property
owners to lay out mitigation options (and financial impacts) . Such a tool would inform mitigation
decision and HMA grant participation. It needs to include real-time insurance benefits, IAHP grants, and
EHP issues so that owners are provided. This conversation can’t be complete without a discussion about
having timely information about insurance benefits for the determinations of substantial damage,
permit needs, and to give the owners the best variety of opportunities for mitigation appropriate to
their situation.
H. 6. (a)Train FCOs, PA and IA field staff to require post-disaster mitigation and incorporate into allhazards mitigation plans and post-disaster response and recovery programs.
H. 6. (b) Ensure that PA staff and contractors have expertise to make decisions about post-disaster
reconstruction of public infrastructure and facilities that incorporate mitigation through complete
application of all work eligible through Stafford Act Section 406 Public Assistance Hazard Mitigation.
Measure accomplishments through defined metrics using reportable tools to demonstrate that every PA
Public Worksheet has been fully evaluated for eligible mitigation opportunities.
H.6. (c) Develop necessary training and tools to ensure full use of Public Assistance 406 Mitigation
Program to repair/replace damaged public infrastructure in a more resilient manner.
H.7. Continue to advocate for HMGP base funding at 15% of eligible federal disaster recovery costs;
with 20% HMGP funding for states with FEMA approved enhanced mitigation plans.
H.8. Continue to work to maintain accurate, current RL and SRL property lists depicting property status
allowing states and local governments to target mitigation programs to these properties.
H.9. Fully expand the state management oversight pilot policy program to all eligible states for
administrative oversight of HMGP, FMA, and PDM.
H.10.(a). Periodically (3-5 years) conduct an independent evaluation of mitigation programs including
PDM, HMGP and FMA to quantify their effectiveness in reducing losses.
H.10.(b) Expand FEMA’s Building Sciences post-disaster Materials Assessment Teams work to more
disasters from multiple hazards to increase knowledge of mitigation performance measures so that a
more comprehensive evaluation of building code and materials performance is evaluated nationwide.
H.11. Evaluate mitigation plans of communities hit by a disaster and summarize lessons learned and
evaluate effectiveness of mitigation plans.
H.12. Encourage state and local mitigation plans to incorporate consideration of cost-effective
infrastructure mitigation investments to increase community resiliency.
H.13. Cross-train code officials and floodplain managers in building code-flood loss reduction programs.
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H.14. Build state capability for mitigation by developing a FEMA/State partnership program for
mitigation modeled on the CAP.
H.15. Firmly clarify and define eligibility for “structural/non-structural” or “major/minor” flood control
projects using FEMA HMA grant programs to ensure that traditional “non-structural” projects are
funded in lieu of structural projects eligible for US Army Corps of Engineers or USDA Natural Resource
Conservation Service funds.
H.16.Promote dissemination of success stories (such as those on FEMA.gov); emphasize mitigation
effects on flood insurance premiums.
H.17. Increase emphasis in state and local mitigation plans to state and local capabilities/programs
and what they can and will do, without federal funding.
H.18. Require a high-level federal interagency (MitFLG?) follow-up review of causes, costs, impacts,
policies, and mitigation response for all major Presidentially-declared disasters. This can be included in
the JFO Hot Wash process at JFO closing or disaster programs close out.
H.19. Advocate for steady HUD, USDA, SBA and other mitigation funding through Stafford Act
amendments. This could prevent uneven federal financial disaster recovery support due to
sequestration or lack of will to fund programs such as Community Development Block Grant – DR or
USDA Emergency Watershed Protection Programs. The full suite of federally-declared disaster recovery
funding programs should consistently available nationwide. H.20. Allow the insured to purchase
additional $30,000 blocks of ICC coverage, over and above the standard $30,000 that is included in the
SFP, to a limit of $150,000 worth of Increased Cost of Compliance (ICC).
H.21. For compliance reasons, allow ICC funds to be accessed by an insured ___ whose structure has
been remapped from an A zone into a Coastal A or V zone.
H.22 Encourage market-driven private-sector incentives for mitigation.
H.23. Develop open-source tools for post-flood damage estimation to better inform post-disaster
mitigation strategies for program/technical assistance/grant targeting, BCA support data, and review
and improvement of local risk reduction policies.
H.24. Develop sustained state and local flood hazard mitigation grant programs that can complement
federal investments in hazard mitigation.
H.25. Evaluate how to implement National Research Council recommendations on benefit-cost analysis
into FEMA’s BCA Tool.
H. 26. Consider and broaden regulations governing FEMA’s BCA policies to include all benefits including
non-market societal and environmental benefits.
H. 27. Conduct a study to determine the advantages/disadvantages of developing unified cost
effectiveness policies and procedures for FEMA and the USACE for flood mitigation projects. .
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H. 29. Continue to develop and apply methods to quantify natural functions/resources Also see K.6.
I. Structural Projects
I.1. (a) Use structural flood control projects only as a last mitigation resort & never to protect
undeveloped or added value development to “protected” land. Delete. This may not be appropriate for
all areas. Communities may need to construct ‘structural flood control projects’ in an undeveloped area
as an enticement for development and the solution could be beneficial in other ways instead of just
environmentally. The project could be part of a bigger plan envisioned by the community. These kinds
of requirements can’t come at the national level.
I.1(b). All lands and property “protected” by structural flood control projects must remain within the
SFHA and required to be regulated and insured. The lands should be designated on FIRMs as AL (for
“levee”).
I.2.(a) Build all structural flood control measures to 500-year protection (to protect federal taxpayer
investment and insurance) even if B/C is cost effective at 100 year. Delete. Again, this is a major
requirement and shouldn’t be made at the national level. This could be a huge burden for some
communities.
I.2. (b) Grandfather structures that provide between 100- and 500-year protection, based on current
and estimated future conditions hydrology, and make preferred risk insurance available. Develop a
mechanism to upgrade those structures to 500-year protection Delete ‘estimated future’ conditions.
These would be based on numerous things that could easily, and in most cases, change. Requiring
structures to be built to ‘future’ conditions proves many times to be a waste of future tax payer dollars.
I.2. (c) Revise automatic method of estimating benefit claims of previously constructed projects, based
only on river elevation fluctuations.
I.3. Prevent or mitigate any adverse impacts (social, economic, environmental) from construction,
repair, rehabilitation of structural projects prior to construction of the project
I.4. (a) Require local sponsor of structural flood control projects to demonstrate financial and technical
capacity for operation and maintenance before project approval or recognition of levees and all
structural and non-structural measures by NFIP, USACE or PL 84-99
1.4. (b) disallow reimbursement of local sponsor expenses that are used to build water resources
projects before the Administration has approved and Congress has authorized the project
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I.5. Oversee and enforce ongoing operation and maintenance of structural and non-structural measures
as a condition of federal support or deny/remove the project from PL 84-99 program
I.6. (a) Use watershed-based planning and coordinate programs when developing water resource
projects and require full analysis and evaluation to include nonstructural components alternatives
analysis prior to funding structural projects.
I-6. (b) Increase emphasis and establish incentives for the use of non-structural approaches in water
resources development and flood risk management programs through revised Principles, Requirements
and Guidelines and other planning tools.
I.7. (a) Perform environmental restoration of natural functions prior to or during repair, rebuilding of
structural projects and implement nonstructural complements
I.7 (b) Suggest full analysis and consideration of removing a structural project as an option to
significant repair or upgrade.
I.8. Map and require flood insurance (rates based on residual risk) and mitigation measures for all
building/development in failure zones associated with dams, levees, diversions, reservoirs
I.9. Require communities with NFIP-recognized structural flood measures to have a multi-hazard
mitigation plan and an emergency action plan Also see H.25
I.10. Moved to I.2. (b)
I.11. Inventory and build database of levees (public and private), general condition, and potentially atrisk development nationwide (number of structures and people) Also see E.7
I.12. Develop an efficient method for local officials to inspect, maintain and repair or remove flood
control structures using a nationally consistent data tool.
I.13. Create national specifications for levees (and other structures) definitions that incorporate
consideration of function, risk, and vulnerability
I.15. Stand up the National Levee Committee of federal agencies and state/local partners to
revise/develop levee design standards to build in resilience, e.g., freeboard, spillways, etc.
I.16. (a) Develop guidance and training on proper inspection and maintenance of levees for accreditation
and recognition by NFIP; include responsibility of and consequences/liability to owner
I.16 (b) Update and revise federal emergency rehabilitation for flood control structures program (P.L.
84-99) to conform cost-sharing with other flood damage reduction programs, reduce federal disaster
costs, reduce risks, and support greater use of flood risk management and non-structural approaches.
I.17. (a) Implement the federal policy that maintenance, inspection, and repair of levees is the
responsibility of levee owner
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I.17 (b) Ensure that project sponsors commit to and continuously meet all conditions of PL 84-99
program or remove the project from the program.
I.18. (a) Enforce the requirement that federal taxpayer funds for levee repair are contingent upon
proper inspection, operation and maintenance by levee owner
I.18. (b) Develop a program to identify levees and other structures with repeated federal emergency
repair and rehabilitation expenditures, and require consideration of a full suite of risk mitigation options
for the structures (similar to NFIP repetitive loss mitigation programs.)
I.19. Develop a national levee safety program to be administered by states, integrated with state dam
and floodplain management programs
I.20. Encourage state dam safety programs by making disaster assistance or other federal funding
contingent on an effective State program; with reflective sliding scale cost share
I.21. Provide incentives for states to remove dams that can/should not be maintained
I.22. Use watershed-based, multi-objective planning to determine fate of aging dams in small
watersheds
I.23. Provide technical assistance for addressing aging dams in small watersheds
I.24. Determine federal taxpayer role in addressing aging dams in small watersheds
I.25. Make public aware of residual risk associated with structures including flood depths and velocities;
use signs and publicize insurance availability as minimum non-regulatory product in all Risk MAP
projects.
I.26. Establish a joint federal/state/regional work group to find ways to enhance levee performance and
set appropriate levels of protection
I.27. Develop consistent guidance for local and regional planning of levees and other structures
I.28. Revise federal agency Guidelines to balance the economic, social and environmental impacts of
water resources projects and to account for public safety in designing flood risk reduction structures—
all in accordance with the new Principles and Requirements
I. 29 (a) Include requirements that Corps projects meet the same wetlands mitigation standards as
other agencies
I.29 (b) Review whether the WRDA 2014 requirement to raise the threshold for automatic independent
review of projects costing greater than $200 million (from previous $45 million) is acceptable.
I.30. Require long term Operation and Maintenance costs be included in BCA of structural and nonstructural projects
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I. 31. Require communities relinquish all federal disaster assistance for future damage below the 100year flood elevation in areas protected by structural measures
I. 32. As part of all structural projects, require that maps be created that are based on failure and
overtopping inundation and those maps be publically available
The maps of areas “protected” by levees need to be some sort of “A-zone” so that the lands are
regulated (elevation required) and flood insurance is mandatory.
I. 34. Require permanent deed notices on all properties protected by structural measures notifying them
of protection and where to get additional information
J. Infrastructure & Public Buildings
J.1. Develop national hazard resilience standards for the location, design, construction, and
reconstruction of all public infrastructure and including alternative locations and taking into account
factors of expected future conditions for cost effective mitigation, increases storm intensity, sea level
rise, etc. during the infrastructure’s expected life; these standards become a condition of federal
funding
J.2. Develop FEMA Public Assistance Program guidelines and standards (including no adverse impact
requirement) required for use of federal funding for local, county, and state transportation departments
to use in the post-disaster repair and reconstruction of damaged roads and bridges using federal
disaster funds and taking into account factors of all expected future conditions during the infrastructure
expected life
J.4. Require utility companies eligible for Public Assistance to account for the flood risk in planning,
design, construction and re-construction of facilities, analyzing the full range of mitigation options
J.6. Make Public Assistance funding contingent upon mitigation measures for any facility substantially
damaged or damaged more than once in 10 years Also see F.6
J.7. Prohibit the use of federal funds to site new public infrastructure in the SFHA that would serve new
development In undeveloped areas
K. Natural & Beneficial Functions/Resources
K.1. Initiate a national study on environmental degradation that results from water resources
development and the impact of that degradation on the economy
K.2. Based on the recommended national study (above), reformulate a statement of federal interest in
water resources policy; shift to sustainability and resilience rather than economic development
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K.3. Develop a resource management strategy to further federal interest in water resources
K.4. Establish a National Riparian Zone Policy Also see I.14
K.5. Determine viability of conservation easements to protect high flood risk and high resource and
erodible lands in light in rising crop prices and food demand
K.6. Continue to examine the economic value of ecosystem services and how to incorporate those
values in all B/C analysis and flood risk and water resource management decisions. Also see P.7
K.7. Clarify Section 404 of Clean Water Act to reduce flood losses, protect riparian areas, wetlands and
waters of the US
K.8. Establish and fund a permanent Environmental Restoration Program within the Corps
K.9. Adjust federal BCA methodology so the USACE and FEMA methodology are consistent
K.10. Emphasize maintenance and protection of natural storage areas in all watersheds; increase the
CRS credit for preservation of storage areas anywhere within the watershed.
K.11. Encourage continuous buffer zones along all waterways and coasts Also see L. 2, L. 7
K.12. Convert Continuous Conservation Reserve Program to a permanent easement program for
riparian buffers nationwide
K.13. Collaborate to integrate/produce resource mapping in conjunction with flood mapping
K.14. Direct FEMA to study whether LOMCs undermine floodplain resources Also see G.2, I.7, K.15, T.8
K.15 Prohibit fill in all SFHA to protect natural resources.
K.15 Require an EA (environmental assessment) for all new floodplain permits unless the community has
done previous assessment for a planning area or the entire community.
K.16 Map and protect from development highly erosive areas, including channel migration zones
adjacent to rivers, streams and coastlines. Not only are these areas risky for development, but
frequently provide some of the most valuable habitat within the watershed.
K.17 Catalog the location of all fills with the SFHA to determine their impact on natural functions,
including storage.
K.18 Increase the CRS minimum points required in NBF for CRS class 4 and 1 communities.
L. Coastal Issues
L.1. Share/redirect navigation fuel tax for coastal and aquatic habitat restoration As minimum
requirement, jurisdiction must have on the books and enforced a provision that any new permit for
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creation of a waterway or road to support resource exploration must be mitigated (filled in and
repopulated/stabilized with endemic species).
Permitted resource mining activities must pay independent entity to track the subsidence during the
extraction period and mitigate the loss of flood risk protection lost due to that subsidence.
L.2. Provide preferential support (grants and cost share) to states & localities whose policy is gradual
retreat from the shoreline. Encourage all coastal states to plan for sea level rise and develop a long term
plan to abandon barrier islands and low lying areas subject to sea level rise.
L.3. Establish a national policy for using a 100-150-years-into- the-future standard for all coastal
management, i.e., erosion, setbacks, sea level rise, subsidence Also see A.3 See notes for A3. What
would this look like? In the past 100 years we have lost vast coastal land, cypress forests, marshes and
wetlands. Is this policy suggesting that we only build coastal restoration projects for areas that will not
be open water in 100 years assuming this same or more accelerated rate?
L.4. (a) Avoid the use of hard structures to protect shorelines unless no adverse impact can be
demonstrated; In order to support resilience, give preference to retreat or soft techniques in all funding
programs
L.4 (b) Require that funding and regulatory decisions to armor shorelines include an evaluation and
assignment of long-term costs to mitigate potential adverse impacts of armoring, including erosion and
scour. Great idea. I understand that one hard armoring project 1/3 washed away in the next storm.
Since it was a mitigation project already (which arguably failed) no PA or mitigation funds could be had
to complete it. That being said, if armoring was required for some temporary timeframe to protect
plantings until they could root and stabilize the soils behind the armoring, the armoring analysis should
take into consideration the second phase.
L.5. Enforce the protection of dunes and mangroves as required in NFIP regulations We who are new at
having a climate to support mangroves could benefit from discussion with historical mangrove
communities about the environmental needs of mangroves/buffer zones, soils, temperature range, etc.
and what soil building can be expected from the life cycle. With that we might use plantings as soft
infrastructure for a living mitigation measure rather than riprap or other structural methodology.
L.6. Provide more funds for purchase of barrier islands and easements on barrier islands, leverage
existing funds after a disaster
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L.7. Require comprehensive planning for coastal acquisition; Require acquired lands to be dedicated to
resource restoration and enhancement to increase level of natural protection, and also to promote public
access to public trust lands.
L.8. Modify National Estuarine Research Reserve provisions to allow acquisition of uplands
L.9. (a) Expand the Coastal Barrier Resource System (CBRS)
L.9. (b) Review and Strengthen monitoring/enforcement /penalties for non-compliance of provisions of
the Coastal Barrier Resources Act
L.10. Do not remove protected natural, wilderness or federally owned areas from Coastal Barrier
Resources System
L.11. (a) Map and manage coastal erosion just like flooding, if it is to be covered by flood insurance
L.11 (b)Delineate all erosion hazard areas on FIRMs in order to increase awareness of erosion hazards
and vulnerability among property owners and local governments. Interesting perspective. I would
support this information on the maps, but would expect the local government and current owners and
users to be a source of the information, not the newly educated. The buyers and developers would be
educated and planners would be able to use this information to best direct development or lack of
development.
L.12. Evaluate coordination among all federal agencies and coastal states of coastal zone management,
floodplain management, and emergency management and identify actions to minimize conflicts, align
programs and missions, and increase efficiencies.
L.13. (a) Provide incentives to encourage coastal communities to have evacuation plans in place and/or
to encourage that approval of coastal development be contingent upon provision for warning and
evacuation plans Also see F.12, F.13, F.14
L.13 (b) Require warning and evacuation plans be tested annually and those tests involve businesses and
the public to improve public awareness.
L.14. Plan and build highways to consider evacuation of the communities they serve
L.15. Improve public awareness of coastal risks and natural resources and functions, preparedness, and
evacuation
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L. 16. Improve coastal flood maps by integrating bathymetric and topographic maps to show wave
runup, storm surge, erosion hazard areas, increased water surface elevations from future conditions
L.17. Evaluate the impact of making flood insurance mandatory for all buildings in coastal storm surge
zones Property ownership is voluntary, and unless the decision privatizes a public good to the detriment
of the public, I don’t see a reason for the government to increase the forced placement of insurance. To
some extent, we would be better off to refuse insurance to camps (many not actually built to any
building code standard) or other substandard structures in an effort to encourage the decommissioning
of those unsafe structures. Insurance encourages people to rebuild when they might not have been
able to afford to without it. People with camps sometimes pocket the insurance doing minimal repairs
and make a profit on the insurance proceeds. There is no limit to the number of times people can flood
and get claims paid, and no connection between these claims numbers or values and the flood insurance
premium. Requiring all structures to get flood insurance will get in revenue, but also increase payments
and eliminate the incentives to mitigate that risk or pay off mortgages to eliminate the burden on the
NFIP. FEMA must then stand firm and not pay disaster funding to people who were not insured
encouraging rebuilding in place.
L.18. LiMWAs should not be optional and should be used on all coastal maps. See A 21 latter is covered
elsewhere Agreed. See comments at A21.
M. Arid Regions
M.1. Develop techniques to identify the nature and associated vulnerability of arid region hazards,
including alluvial fans and post-wildfire conditions
M.2. (a)Continually update flood risk mapping approaches for arid regions; due to unique flow path
uncertainty in arid regions, a model capable of handling such uncertain flow path, such as those having
the capability of simulating probabilistic or stochastic features, is required. Also see A.4
M.2. (b) Find ways to overcome the past problem that over the years, delineation techniques have been
allowed that failed to recognize the flow path uncertainty in arid regions, thus unintentionally reducing
the extent of area where the regulations applied
M.3.(c) Residential and commercial development within the Alluvial Fan areas should be avoided or
highly restricted because the nature of floods in arid regions is not simply the inundation by a certain
depth of water, but rather what the floodwaters are carrying and how uncertain the flow path is due to
erosive forces, movable stream beds and post-wildfire conditions
M.3. Develop management techniques for arid region flood hazards, tied to the nature of the risks
M.4. FEMA should resume the needed arid regions research that was started with the 1985 DMA study
and the 1996 National Academy study. (Arid Regions Committee: Make recommendations on specific
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steps to be taken in order to characterize, identify, map, and mitigate hazardous flood processes for
areas subject to alluvial fan flooding.
N. Special Flood-related Hazards
N.1. Require inclusion of unique hazards (erosion, subsidence, closed lake basins, frazil ice, ice jams,
tsunamis, debris flow and mud slides) in state/local hazard mitigation plans
N.2. Develop techniques for mapping, mitigation and management of special hazards Also see A.2, A.3,
A.4
O. Disaster Management & Assistance
O.1. Implement the Emergency Management Assistance Compact so that it covers key aspects of the
mitigation and recovery phases
O.2. Restore FEMA to independent agency status;
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
O.4. Make the availability of and amount (sliding-cost-share)of disaster assistance contingent upon
taking local/state mitigation action
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 pre-disaster
mitigation program for which hazards pose a significant threat in the plan .
O.6. For natural disasters in flood prone communities, make disaster assistance contingent upon NFIP
participation, compliance, and maintenance of insurance
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
O.8. Expand steam gauging network technologies to flood warning systems. O.10. Establish a combined
review process for community/state compliance, mitigation, enforcement after a flood
O.11. Establish a comprehensive set of emergency rules for funding, cost-sharing, and priorities so
federal programs after a disaster are consistent
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
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O.14. Review PA and IAHP and all federal agency post disaster programs for consistency with all relevant
federal Executive Orders (especially resilience and climate change)
O.16. Revise Stafford Act provisions to allow reimbursement of communities for post-disaster damage
assessments, substantial damage determination, ordinance administration, permitting up to 24 months
after disaster
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 .
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
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 8499 for example consider non-structural measures )
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 and
used as an indicator of a of a successful disaster management and recovery
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.
O. 24. Assist in Building State Capability Including Mechanisms to Assist with Catastrophic and Multiple
Events.
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.
P. Economic Methods and Policies
P.1. Develop and transition to a National Economic resilience/Sustainability standard instead of
National Economic Development standard for water resource projects
P.8. Enable and support federal interagency and interdepartmental water policy coordinating
mechanisms to implement Principles, Requirements and Guidelines
P.9. Upgrade agency Guidelines to reflect the new Principles and Requirements to include sustainability;
account for all benefits; provide greater emphasis on nonstructural; and to balance economic, social and
environmental concerns
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P.11. Direct and fund a new evaluation of the use of risk-based analysis in the design and construction
of flood risk reduction structures
P.12. Provide guidance for the use of risk-based analysis for projects in high-risk areas (urban levees)
P.15. Modify the Corps’ standard cost-sharing formula to provide a 75/25 federal/local ratio for all
nonstructural projects
Q. Partnerships & Incentives
Q.1. Provide incentives for the acceptance of responsibility for flood risk by citizens, states,
communities, private sector Also see R.1–13; S1–15; T.1–12
Q.4. Make receipt of any federal disaster assistance (public or private) contingent upon taking
mitigation measures and the purchase of insurance
Q.5. Make Public Assistance grant eligibility contingent on NFIP participation and compliance and on
maintaining flood insurance
Q.7. Amend existing law so that communities would be allowed to bank mitigation expenditures as
non-federal share of next disaster
Q.8. Make all flood related mitigation funding (including levee and dam funds) contingent on having a
comprehensive, mitigation plan that will support community resilience/sustainability.
Q.9. Support and fund incentives for sustainable uses of floodprone agricultural lands
Q.15 Explore use of true delegation model to move responsibility for NFIP activities to states (mapping,
monitoring communities for compliance, technical assistance, training, etc.)
Q. 18. Federal agencies should encourage integration of certification programs for the International
Codes and for floodplain management (CFM)
Q.20. Prohibit the use of federal funds to build any infrastructure to serve currently undeveloped SFHA.
Q. 21.Reform the casualty loss deduction to better target the deduction as well as incentivize those that
have mitigated. For example, limits could be set as to the number of times a person could claim the
deduction without first mitigating as well as a means tested system to limit incomes of claimants.
Q. 22. Develop a hazard mitigation tax credit much like energy efficiency tax credits that are given to
property owners.
Q. 23. Allow for tax advantaged disaster savings accounts
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Q. 24. Provide specific IRS guidance more broadly exempting cost effective mitigation assistance from
and funding source from federal taxes. Currently only FEMA mitigation programs have a specific
exemption.
R. Federal Leadership
R.1. Establish high-level coordinating mechanism for federal water resources policy
R.2. Establish a National Flood Risk Management Policy
R.3. Adopt a watershed-based, comprehensive approach for all federal water resources activities and
programs
R.4. {State who will} evaluate compliance with federal EO on floodplain management to ensure 500year protection for critical facilities; ensuring access to and fully operational facilities during 500-year
flood; avoiding floodplain when possible; using future conditions in decision-making; avoiding adverse
impacts
R.5. Assign responsibility for oversight of EO 11988 compliance to somewhere in Administration
R.6. Require all federal agencies to issue new floodplain management EO guidance that reflects other
EO’s on resilience, sustainability and climate change, with stronger mechanisms for monitoring,
reporting, enforcement and accountability; (example; Require that all Federally funded transportation
projects incorporate comprehensive flood and storm hazard mitigation design standards.
R.7. Enforce all lease restrictions on federally leased floodprone land, especially denial of flood
insurance, and non-renewal after expiration of the lease.
R.8. FEMA should Establish a working group to assess and implement recommendations of 2012 report
on “Rethinking the NFIP”
R.9. ASFPM should analyze “Effective State Programs” to work with states to encourage states to move
beyond basic and toward model flood risk management programs
R.10. Provide full funding for flood risk management data gathering and development (GIS,
streamgaging, forecasting, mapping, Integrated Ocean Observing System, research)
R.11. Give FEMA Director discretionary authority (with input from localities and the state) to require
communities to use advisory maps and BFEs (It could be a requirement of CRS communities to use
advisory or preliminary maps as best available data.)
R.12. Support professional certification programs for floodplain managers, adjusters, agents, and
others; provide more insurance-related training via the NFIP Training Contractor.
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R.13. Provide generous and reliable funding for federal programs that generate the most long-term
impact, i.e., technical assistance and state/local capability-building
R. 14. Make NFIP participation and disaster assistance contingent upon states’ ensuring that their
funding, regulations, and programs comply with the NFIP; with monitoring and penalties for
noncompliance
R. 15. Provide adequate resources and opportunities for collaboration with state and local partners of
interagency coordination entities such as the Federal Interagency Floodplain Management Task Force
and MITigation Federal Leadership Group (MitFLG).
R. 16. Consider shifting to a national model that delegates floodplain management authority to states,
with incentives provided through ALL federal grants, disaster relief, etc.
R. 17. Support examinations of alternative paradigms for national flood policy and programs, including
governance, mapping, avoidance of flood risk areas and flood insurance
R. 18. Provide incentives to encourage states to issue and enforce effective executive orders on
floodplain management
R.19. Establish strong federal floodplain management rules for federal investments and actions that are
based on the principles of long term resiliency – including from climate change, use of natural
ecosystems for resilience/sustainability and flood damage reduction.
R. 21. Provide incentives (CRS, disaster relief and others) for all state and local managers to be CFMs.
R. 23. FEMA should develop and implement a CAP-SSSE type program to assist states in building state
hazard mitigation capability.
S. Building State & Local Capability
S.1. Support and provide incentives to states in efforts to encourage progressive state and local
programs and activities, including NAI approaches (explore allowing states to participate in the CRS
program)
S.3. Increase funding for federal programs that provide technical expertise that supports state
mitigation strategies and the production of mitigation grant applications
, and integrate state dam and levee safety programs with floodplain management Also see A.14 The
LOMR LOMA process needs a complete review and having states and localities review submittals is one
step.
S.5. Redesign CAP and other delegation programs to emphasize building state and local capability
instead of simply buying state services
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S. 6. Negotiate CAP participation individually with each state with each change of state administration,
and require governor-level commitment from state, using many forms of federal funding as an incentive
S.7. Same as above—change to: States need to upgrade their entire programs: regulations, intraagency coordination, policies on where state emergency management funds are spent, their mitigation
efforts, etc. There should be some minimum standards for state programs, which ASFPM should work
with states/feds to create and promote.
S.9. Tie CAP funding to NFIP and flood disaster reduction-related needs and add annual inflation-indexed
increases
S.10. Provide incentives and disincentives to encourage states to view CAP as auxiliary funding to state
floodplain management programs, not sole source
S.11. Properly fund CRS verification program to ensure CRS credits are properly earned or class rating
reduced.
S.13. Publicize successful activities of CRS communities – why they are successful, how the activity
reduces risk and/or promotes sustainability and how they got it all done
S.14. Develop, fund, and implement technical and financial support and other incentives for localities to
conduct its own management and mitigation programs
S.15. Provide incentives to encourage communities to integrate floodplain management with land use
and watershed conservation plans. Require for credit of flood plans in CRS.
S.16. Conduct independent reviews of state and local programs to determine effectiveness on a five year
cycle.
S.17 All FEMA Regions should annually host meeting/training with State NFIP coordinators and SHMOs
T. Individual Accountability
T.1. Continue to move to actuarially sound flood insurance rates over time for all buildings
T.2. Continue movement towards actuarial rates for pre-FIRM residences as per HFIAA; put them on
the same path as others if they have a loss
T.3. Continue increasing insurance rates on repetitive loss structures; and move to full actuarial rates if
SRL owners refuse an offer of mitigation assistance
T.4. (a) Encourage private insurance programs if the flood mapping, management and mitigation
aspects can be accounted for
T.6. Establish procedure by which FEMA Director can require mitigation for a structure that has filed a
flood damage claim
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T.8 Discontinue practice of waiving the flood insurance requirement after issuance of LOMR-Fs ; apply
risk-based rates instead. Also see F.5, G.2, K.13
T.9. Expand outreach to the public, adjusters, and insurance agents about repetitive losses and how ICC
can be a most effective tool to mitigate the flood risk and reduce insurance premiums
T.10. Appropriate additional funding for public outreach on flood risk and insurance, especially for
communities with levees
T.11. Clearly communicate flood risk (e.g. policy renewal should show what actuarial rate would be as
well as current rate); uncertainty in forecasts, better terminology; awareness campaigns
T.12 Enhance the outreach capabilities of FEA disaster, mitigation, insurance and mapping programs to
promote a better understanding of individual risk and options to deal with the risk.
T.13. Ensure actual cost of flood insurance is annually communicated clearly and directly to policy
holders, regardless of discounts or subsidies
U. Agriculture Policies
U.1. Evaluate federal agricultural policies and their impact on flood loss reduction and floodplain
function and resources; then use this data to integrate federal agencies flood risk programs into other
programs (FIFM-TF or MitFLG)
U.2. Increase funding for popular and effective agricultural conservation programs that protect natural
values of floodprone lands, floodplain functions and natural ecosystem resources
U.3. Integrate agriculture programs with flood loss reduction and floodplain management programs
U.4. Tie the Conservation Reserve Program and related agricultural programs to market prices of
commodities Also see Q.9, Q.10, Q.11, Q.12; I.14; K.13
V. Climate Change
V.1. Evaluate regional/local vulnerability of U.S. population centers to climate change impacts and
provide adaptation options
V.1.a Develop unified national policy/response plan to deal with the impacts of climate change,
especially sea level rise, including mitigation prior to an event and response after an event. Develop
minimum standards for the expenditure of all federal dollars following a disaster to account for
anticipated climate impacts..
V.2. Support/participate in data collection & analysis on impacts of and adaptation to climate change
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V.3. Require analysis of impacts & adaptations to climate in all mitigation planning.
V.4. Issue Executive Order to compel federal agency consideration of climate change impacts Also see
L.3
V.5. Revise federal agencies BCA methods to include projected impacts of climate change over the life
of the project.
V.6. Develop grant guidance to encourage/incentivize projects to address climate change
V.7. Require all Class 7 and better CRS communities to consider and plan for climate change in their
floodplain management plans, maps and regulations.
V.8 Require all Class 4 and better CRS communities to include the impacts of land use and climate
changes through 2100 in their mapping, planning, and regulations.
W. Beach Nourishment
W.1. Develop guidance to determine when beach re- nourishment is in the federal interest
W.2. Do not use beach nourishment in any federally funded projects, unless federal interest will be met
W.3: Require that the Federal interest in beach nourishment be demonstrated to exceed the Federal
interest in other, more permanent mitigation options that are more sustainable and don’t require
ongoing expenditures. At least reduce the federal cost share for beach nourishment
W.4: Require that benefit-cost analyses for Federally funded nourishment projects identify and evaluate
full costs, including periodic renourishment, increased costs for locating and acquiring suitable material,
long-term project maintenance and required protection of induced development and redevelopment.
W.5: Revise the cost-sharing agreements for Federal nourishment projects to shift more of the cost to
non-Federal sponsors who receive the majority of the project benefits (suggest 35% Federal – 65% nonFederal as a start).
W.6: Require that Federal nourishment projects be monitored and evaluated periodically to determine if
the project has actually performed as planned and justified based on costs, to determine if the project
should be abandoned or the design should be amended to reflect changing conditions, and to increase
efficiencies, reduce costs and provide greater benefits.
W.7: Include specific requirements (not guidance) for public access to and use of beaches nourished with
Federal dollars as a condition of funding, including minimum number of access points, parking and rest
rooms that provide “meaningful” public access.
W.8: Require that planning, benefit-cost analyses, design and construction of Federal nourishment
projects account for sea level rise.
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W.9: Require benefit cost analyses for Federal nourishment projects to consider all mitigation
alternatives, including acquisition and land use management options, and to demonstrate that these
options are not cost-beneficial before considering nourishment.
X. Resilience
NOTE: this is a suggested added area of policy. Feel free to suggest national flood policy that relates to
this. In the final document, we will likely pull items from the remainder of the list that may fit more
appropriately in the resilience category and move them here.
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