ASFPM NFPPR 2015
K. Natural & Beneficial Functions
Recommendation
Leverage existing programs for NBF
Explanation/Rationale
K.1. Utilize the recent farm bill to ensure the benefits of
conservation easements to protect high flood risk, high
resource value and erodible lands in light in rising crop
prices and food demand. Review the impact of existing
programs and suggest improvements to promote
sustainable uses. [USDA, FSA, NRCS, EPA, FEMA]. also
see K.9
Should include 1) review the impact of existing programs
and then 2) suggest how to implement improvements.
K.2. (a) Promote and expand the use of existing
easement programs on agricultural and undeveloped
lands to protect areas with high flood risk, highly
erodible soils, loss of floodplain connectivity, and high
resource value for providing ecosystem functions. This
could include conservation easements to maintain
farmland with practices that create flood storage areas
during large events. [NRCS, States]
Build off existing Conservation programs so not going for
new money programs or authorization
High crop prices and subsidized crop insurance have led
to the farming of marginal land and withdrawal of
vulnerable lands from conservation programs. This
leads to increased runoff from the newly farmed land,
more drainage of land, reduced water quality, and
increased downstream flooding due to the reduction in
storage on the land and within the soil.
Considerations for easements would include what type
of farm management practices would be acceptable,
how to compensate crop losses given the public benefit
provided through farm field flood storage.
K.2 (b). Convert Continuous Conservation Reserve
Term limited easements do not serve the longer range
Program to a permanent easement program for
public interest.
riparian buffers nationwide, or look to establish riparian
habitat banks for projects and areas where riparian
buffers or easements are not possible. [NRCS, states]
K.3. (a)BUFFERS AND RIPARIAN ZONES
Establish a National Riparian Zone Policy. As part of
this policy encourage continuous buffer zones along all
waterways and coasts to preserve the ecosystem
services and reduce flood damages.
[CEQ, FEMA. USDA, HUD; EPA; states]
Also see C.5, I.14, L. 2, L. 7, C.5
This could be considered as extra points in grant
applications for those communities who use it because it
reduces flood losses and benefits water quality.
(b) Encourage continuous buffer zones along all
waterways and coasts [FEMA; NOAA; NRCS; HUD; EPA]
Also see L. 2, L.7
Buffers are one of the most effective means to protect
both water quality and habitat and to reduce flood
damages and flood insurance costs
K.3. (c) States and local communities should require
building setbacks to provide natural buffers on all
Some states have buffers in Shoreland mgt programs.
Often we see grading right to the apex of the bank and
NFPPR rec and rationale
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streams and coasts to protect water quality, flood
storage, ecosystem services and development outside
of the buffers. [States, MitFLG]
K.4. In all federal policy documents provide increased
emphasis on social and environmental values,
sustainability and resilience and not just economic
development [CEQ, all fed effected agencies]
K.5. MIT-FLG should review implementation of Section
404 of the Clean Water Act to determine how it can
encourage or compliment flood loss reduction efforts
by better protecting riparian areas, wetlands and
waters of the US. A requirement to maintain buffers
around existing waterway/wetlands should be
established and implemented.
[MitFLG; USACE; FEMA; EPA,]
New or expanded approaches
K.6. Establish and fund a permanent Environmental
Restoration Program within the Corps (not tied to
Section 1135) for Corps projects to restore habitat and
watersheds throughout the nation. Projects should
have a total construction cost of not more than $50
million and an annual budget of not less than $1 Billion.
[Congress, USACE, NOAA, FWS, NRCS, EPA]
K.7. NOAA PROGRAMS
(a) Expand the Coastal and Estuarine Land Conservation
Program (CELC) in NOAA to include critical non-coastal
riparian habitat and expand the funding to recognize
the importance of maintaining coastal and riverine
riparian habitat and providing buffers for climate
change. [NOAA, congress if needed]
(b) Reauthorize the CZMA (long-term) and include a
minimum of $50 million per year for the Coastal and
Estuarine Land Conservation Program (CELC).
[Congress, NOAA]
the subsequent failure of the previously stable bank.
Fed programs can incentivize this in mitigation grant
process by extra points because it reduces flood losses
and protects water quality and habitat and future
disaster costs. There is CRS credit for these buffers.
More emphasis on resilience and sustainability needed.
The other key means of accomplishing this would be
finalizing new, clear guidance under the National
Environmental Policy Act. In 2010, CEQ issued new draft
guidance for public comment on these points and
especially future conditions analysis for climate changerelated environmental review under NEPA
The impact of any permit application on flood levels,
velocity, erosion and on other properties should always
be analyzed and mitigated before the permit is allowed
to proceed or during construction.
Corps is the agency that does projects so they should be
the ones doing the work. (LA River)
As an alternative, or in addition, we should support the
establishment of grant programs run out of NOAA, NRCs
and other agencies for restoration work.
This is the rare program at the federal level dedicated to
acquiring and preserving land. There does appear to be
statutory flexibility in existing law for this.
Reauthorization of CZMA has been virtually dead for
more than a decade (other than year to year
extensions).
LL—what about LAWCON?
NFPPR rec and rationale
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K.8. FEMA, communities and states should prohibit fill
in all SFHAs to protect the natural and beneficial
functions of floodplains, including storage, or identify
and implement incentives beyond CRS to communities
that adopt this higher measure. [FEMA, communities,
states] See F ?
K.9. Where listed species or their habitat is present an
environmental assessment should be required for all
floodplain development permits unless local standards
meet the requirements of the relevant biological
opinion. [FEMA, NMFS, states, communities]
Fill is beneficial to the person doing the filling, but can
increase flood risk on others. This recommendation is a
basic NAI concept and it is credited in CRS.
K.10. FEMA should map erosion zones and work with its
state and local partners to create regulations for those
erosion zones to protect development from highly
erosive areas including channel migration zones
adjacent to rivers or streams and erosion areas along
coastlines, and maintain high quality habitat. [FEMA,
states, NGOs] See A ?
This mapping has been done by some State or local
jurisdictions to a standard that should be accepted by
FEMA as the official map. See Vermont and Washington
models for mapping standards.
Not only are these areas risky for development, but they
frequently provide some of the most valuable habitat
within the watershed
Is this adequately covered in A or F?
K.11. Increase the CRS minimum points required in
elements that credit natural floodplain functions for
CRS class 4 and 1 communities. [FEMA]
Are we asking for more pts for NBF or more points
needed to get the credit?
Evaluation of programs and Studies
K.12. FLOODPLAIN FILLING TRACKING/IMPACTS
(a) Require communities to catalog and annually report
the location and amount of all fills within the SFHA and
to identify if offsetting storage has been created. This
will allow FEMA over time to be able to measure the
impact of fill on flood stages and habitat. [FEMA;
States]
The application of ESA to the NFIP is being refined by the
courts, and FEMA and National Marine Fisheries Service
are collaborating on implementation of appropriate
measures where endangered species exist.
More emphasis on NBF reduces hazards, promotes
many other beneficial functions and services, and the
current requirements are too low to be effective.
See Charlotte-Mecklenburg studies that provide a model
of how much impact such fill has on flood levels.
The data is usually included as part of either the building
permit or the grading permit. It is just the reporting &
tracking process that needs to be done. Very important
idea; careful direction for operationalizing is necessary.
(b) Perform a study to determine the impacts of
floodplain fill since the inception of the NFIP has had on
flood levels and ecosystem services? (There may be a
tie with mapping here if they also want to propose)
[FEMA, NSF, GAO; academia]
This would inform how to treat fill in the NFIP or State
FPM programs, and should include examples of how
various states/communities deal with this issue. GAO
might be the appropriate body to do a report that could
lead to a useful study.
K.13 Require that funding and regulatory decisions to
armor shorelines, stream banks or lakeshores include
an evaluation and assignment of long-term costs to
mitigate the adverse impacts of armoring, including
erosion, scour and habitat as well as the long term cost
There is great importance in maintaining and enhancing
NBF as a critical part of overall sustainable flood risk
reduction. The preference should be to not armor the
site except in extremely rare instances
NFPPR rec and rationale
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of Operation and Maintenance. This may require
modifications to the Nationwide 404 permit for private
bulkheads and sea walls. see also L.4 and I. ?
[Corps, CEQ, States]
K.14. Initiate a national study on environmental
degradation that results from water resources
development and the impact of that degradation on
the economy [NSF; MitFLG; NAS]
K.15. Collaborate to identify ecosystem functions in
conjunction with flood mapping and to
integrate/create/enhance those functions in managing
flood risk. [MitFLG; FEMA; EPA, FWS, NWI, USGS]
NFPPR rec and rationale
DRC: – I’m not absolutely sure, but I believe there is a
Section 404 Nationwide Permit for bulkheads and sea
walls that private owners want to build – I’m not sure
what the maximum size is. If it’s a nationwide permit
(NWP), then this information will never get reported, at
least for a lot of private projects.
The intent is to analyze the LOSS of water resources and
riverine/coastal ecosystems that has occurred over the
last century, and what impact that has on ecosystems,
added flooding and quality of life for economic impact
For example, groundwater recharge areas may not show
up as a mapped “resource”, but certainly they provide a
function that needs to be mapped and protected.
See Vermont model for mapping
Some of this is specifically required by BW -12 TMAC and
NFIP mapping, and the case should be made for a robust
collaboration and good justification as to why this
should be a priority.
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