National Flood Policy—ASFPM 2015 Recommendations
F. Floodplain Development Standards, Regulations and Codes
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, limiting new
structures in SFHA) 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
F.1.c. Require participating states and their
communities to adopt the IRC and IRC without
exception or change in order to participate in the
NFIP. (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 multi-story, $multi-million
homes at-grade.)
F.1.(c) Require communities to adopt a minimum
of 1’ Freeboard or the 2015 ICC Residential Code
(that will require +1’ Freeboard) as a condition of
receiving PA assistance following a disaster event
FRM std comes in here somewhere
(Referring to section F in general) 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. This could
be rec here and in G insurance
a. This should also include what regulations should
not be included in national regulations or only
minimal requirements, leaving the local
communities to regulate in a way that better suits
their community. Maybe these would include
climate change, etc.
a. FEMA should create NFIP regulations revisions
workgroups for riverine, coastal, arid regions,
and/or east and west (of Mississippi River) NFIP
communities. Interesting-LL
b. Add New F.1.(c) Require communities to adopt a
minimum of 1’ Freeboard or the 2015 ICC
Residential Code (that will require +1’ Freeboard)
as a condition of receiving PA assistance following
a disaster event]
SEEMS TO OVERLAP OR PERHAPS DUPLICATE
SEVERAL EARLIER RECOMMENDATIONS
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
-- To increase NFIP knowledge and compliance, a
minimum FEMA requirement should be the local
floodplain managers or at least one permitting
staff to be an ASFPM Certified Floodplain Manager
NFPPR Combined comm rec and comments
This may be a slippery slope in light of the recent
changes and could result in making some
communities ineligible.
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
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(CFM) similar to CRS Activity 432.o. Regulations
administration (RA). Also see F.10.
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 flood 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.3. Require mitigation measures [flood risk
reduction regulations] (elevation, zoning,
insurance) in failure zones associated with dams,
levees, diversions, and reservoirs to reduce
residual risk and taxpayer costs, accounting for
varying degrees of risk and consequences. This
can be done in association with A1.
Require, or provide either incentives or less
coverage in these areas?
F.4.a Encourage adoption of flood ordinances
that require 2 or more- feet of freeboard above
BFE for new construction in riverine areas and 3-4
feet of freeboard in coastal areas prefer w/o
change_LL
Comment received: good objective – will get much
push back.
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 risk
reduction structures—is this mapping, H&H, or
regs or ???
F.4.c Require the use of the moderate risk
projection of sea level rise by 2100 for all mapping
and regulation and mitigation funding? (also for
the expenditure of any and all federal funds,
construction and technical assistance.
F.4. (d) Require 500’ setback from mean low
water for new construction in coastal areas that
NFPPR Combined comm rec and comments
AS YOU KNOW, MITIGATION IS RARELY
"REQUIRED." DON'T YOU MEAN THAT SUCH
FAILURE ZONES SHOULD BE MAPPED AS S.F.H.A.s?
AND LEVEE-PROTECTED AREAS ARE THEIR OWN
CAN OF WORMS, COVERED UNDER THE "RESIDUAL
RISK" RECOMMENDATIONS
In order for success, this step must be
accomplished with additional funding for
mitigation projects and incorporation of an
income-sensitivity consideration.
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.
a. Honeycutt: Only NFIP regulations?
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have a coastal erosion rate of 5’ to 10’ per year;
Require a minimum of 1,000’ setback if the
coastal erosion rate exceeds 10’ per year.
Above rec relates to erosion setback, which we
should address
Not wanting to get ahead of national policy that
may or may not be pending (ahem… Fed Flood Risk
Standard), but ASFPM may want to see whether
it’s worthwhile to look at either a more
comprehensive call for freeboard (i.e., beyond just
NFIP), or leave this as an NFIP issue here and plan
to add similar calls for freeboard in Federal or
federally funded investments in other sections of
the document.—yes in mitigation/fed leadership-L
a. Many local communities have already gone to
this requirement. 1’ should remain as minimum
requirement at federal level.
a. Honeycutt: Again, another rec prescribing one
approach to consider sea-level rise. See comments
offered elsewhere, and delete this one.
a. FEMA should clarify the elevation and freeboard
requirements above natural grade in approximate
Zone A, with no BFE, in 44 CFR 60.3(b).
c. This is connected to A3 but not in full agreement
with it.
F.5. (a) Revise NFIP regulations to require a no rise,
no velocity increase, 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 or mitigating the proposed effects.
(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; however, accommodate existing
structures and structures impacted by channel
movement.
NFPPR Combined comm rec and comments
c. A 100 year projection for insurance does not
make sense when the policy term is one year.
Perhaps in high risk areas, but probably not all.
b. Does this recommendation refer to new
structures or existing ones as well? Clarify.
Suggestion is to say no “new or substantially
improved habitable structures…”
b. Achievement maybe difficult given that this is a
local land-use decision, hence the suggestion for
the inclusion of incentives
b. LB=This should be revised to state that NO
structures of any kind should be allowed in a
floodway. And if a structure is in a floodway and it
is damaged more than 50% of its value, it must be
removed from the floodway. We have got to end
the current regulatory process that buildings can
be rebuilt in a floodway if the “footprint” of the
building is not increased. Also, the more than 50%
substantial improvement must include all
cumulative improvements that have occurred over
time.
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F.6. Revise the NFIP regulations to define critical
facilities, prohibit flood insurance coverage for
them in regulated floodplain unless no alternative
exists and they are elevated to above 0.2% annual
chance level including freeboard and estimated
future conditions incorporated, require 0.2%
annual chance protection with access and
operability and evacuation during the 500 year
event, and set other standards as needed. It may
be practical to prepare and implement plans to
provide the services of a critical facility at an
alternate location or in spite of the event. It may
be more economical to provide numerous,
smaller, distributed facilities, each of which may
be at risk for lesser events, but where it is unlikely
that all of the facilities would be unavailable during
an event. Requirements for critical facility should
respect the warning time of the events from which
the facility is being protected. Design for
protection from hurricanes (warning time: days)
might yield different results than design for
protection from flash flood (warning time :
minutes to none). Also see J.1–7
Buss-This should be revised to state that NO
structures of any kind should be allowed in a
floodway. And if a structure is in a floodway and it
is damaged more than 50% of its value, it must be
removed from the floodway. We have got to end
the current regulatory process that buildings can
be rebuilt in a floodway if the “footprint” of the
building is not increased. Also, the more than 50%
substantial improvement must include all
cumulative improvements that have occurred over
time.
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 non-published
NFPPR Combined comm rec and comments
Add “critical facilities” to section J. Infrastructure &
Public Buildings. Include the flood insurance
requirement for public buildings, which may be
critical facilities, in sections G. Flood Insurance or J
Consider adding a F.6(b) Rewrite or issue guidance
for evaluation of practicable alternatives to clarify
compliance with 44 CFR 65.7(a) Floodway revisions
and 44 CFR 65.12(a)(2) Revision of FIRMs to reflect
BFEs caused by proposed encroachments.
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.
Fire Station ISO rating do play a major part I this
regulation. Requiring the access to be above .02%
event is imposable at times.
4 CFR 60.3(c)(10) includes “until a regulatory
floodway is designated” and many communities
have difficulty tracking the cumulative effect of
encroachments. An NFIP community should
regulate encroachments to prevent adverse
impacts and it may not be possible to get
agreement by all impacted property owners. FEMA
should consider a time frame such as a 10-year
period to track the cumulative effect of
encroachments, then allow a low cost LOMC
process for the NFIP community to revise the
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BFEs.
floodplain to reflect any encroachments, revised
BFEs, and a new floodway.
Cannot figure out what this is saying.
Another option is to require a communityaccepted flood study before new structures can be
built or fill used.
F.8. Revise the NFIP regulations to require initial
floodplain mapping that matches topography for
any USGS blue line streams without an
existing/mapped SFHA 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
Intent of this recommendation is hard to
understand as it is written. Is the proposal that all
USGS blueline streams in urban areas be mapped
as FEMA regulatory floodplains? USGS blueline
streams often go further up in the watershed than
a FEMA floodplain cutoff does. Many communities
map and regulate their own regulatory floodplains
higher up in the watershed than the FEMA
floodplain cutoff. Communities should have their
preference on whether to extend the FEMA
floodplain further up in the watershed or not.
The topography for USGS blue line streams is
usually not as detailed (20 to 40 feet Contour
Interval) as for subdivisions (2-foot Contour
Interval). Communities typically require new
detailed topography or cross-sections for hydraulic
models with a floodway analysis, especially for
subdivisions and large scale developments.
“matches topography”?
F.9. (a) Revise the NFIP regulations to lower the
threshold of “large” developments required to
submit 1% annual chance flood data (and
recommended floodway analyses) Explore
alignment of thresholds with requirements of the
CWA.
F.9. (b) During final platting of all new subdivision
lots require that all new subdivision lots created
have enough natural buildable ground above the
BFE to contain the entire building envelope This
would not be applicable to special types of
construction, such as when building on pilings.
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
NFPPR Combined comm rec and comments
Need to define “large scale development
Specify threshold
For all suggestions of F.9, an incentive beyond the
CRS program, such as greater competitive ranking
or greater federal cost-share for federal mitigation
grants or other community funding, should be
developed to acknowledge communities that
a. or require BFE data in A zones for any new
primary structures/non-accessory structures. If a
lower threshold is to be set for large
developments, it could be lowered to 2 or more
structures or for developments greater than 1
acre.
a. The threshold should be two or more structures
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by a state.
and 1 acre or more.
F.9. (d) Require improved stormwater
management standards for all new subdivisions
and large scale sites that address lower frequency
events (50 or 100-yr events vs. 2- 5-year events)
and address how that water will be handled.
a. Not sure what is meant here????
If this refers to thresholds for stormwater
construction permits, alignment may not be
appropriate due to the 2-tiered requirement for
erosion/sediment control and water
quality/quantity control. Also the area of soil
disturbed is not applicable to subdivisions unless
you want to require that the whole subdivision be
included since eventually the majority of the site
will be disturbed during house construction
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), but not necessarily mapped to the
parcel level. To avoid a duplication of effort,
hazards can be incorporated by reference.
a. These draft recommendations for subdivisions
and large developments can be addressed in some
NFIP regulations, International Building Codes,
local development standards including stormwater
management or local subdivision regulations. The
NFIP regulations can be revised or expanded, such
as 44 CFR 60.3(a)(4) that requires the community
to review subdivision proposals to be reasonably
safe from flooding. Since many communities have
difficulty regulating subdivisions, clarify 44 CFR
65.3 for physical changes affecting flooding
conditions, to require a LOMC for all subdivisions
triggered by any development in the SFHA
(grading, fill, drainage structures, buildings,
utilities, etc.). Also clarify that 44 CFR 60.2(h)
modified data reflecting natural or man-made
physical changes and 60.3(b)(6 & 7) altered or
relocated portion of any watercourse is
maintained, refer to a LOMC requirement. FEMA
could provide new NFIP regulations and more
specific guidance for subdivisions and large
developments, especially for small NFIP
communities with no development standards or
subdivision regulations.
b. 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
NFPPR Combined comm rec and comments
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not above the BFE, would further the appearance
that this is indeed our agenda.
d. Delete. This should be left to the local
community’s decision.
d. What agency or party is recommended to
REQUIRE the stated 50-100 year event stormwater
management standards that are mostly applied to
development outside of the SFHA? Those
standards are the role and responsibility of
individual communities. Many communities
already do design to the 100 year event on all
storm sewer systems whether in the floodplain or
not.
d. 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.
e. Delete. Very cumbersome requirement for
smaller communities & developers.
e. Subdivision regulations can include the SFHA
and floodway to be identified and delineated on
plats and plat notes to identify CLOMRs with case
numbers, permitting requirements for specific lots,
future LOMCs, existing natural hazards, riparian
habitat, ESA areas, etc.
F.10 (a)Develop and implement effective
monitoring, probation and suspension guidance
and standards for better NFIP compliance for all
NFIP participating communities and include an
NFPPR Combined comm rec and comments
Comment received: need to specify level of
inspection – inside/outside? – nobody is going to
allow an inside inspection by the community
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incentives-based program to help assist
communities with better local ownership and
responsibility.
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.
Also phrased “For all structures in Special Flood
Hazard Areas with enclosures below the BFE, the
community must be allowed to inspect properties
at will to ensure compliance / continued
compliance with local regulations / the NFIP, and
especially at any transfer of the property, in order
for the community to remain in the National Flood
Insurance Program. At a minimum the structure
must be inspected by the community, and
documented that such an inspection has been
made, at least once a year.”
F.11. Revise the NFIP regulations to include
identification and management measures for
subsidence related to flood risk management. Also
see N.2
a. Use the NFIP Guidance for Conducting
Community Assistance Contacts and Community
Assistance Visits FEMA F-776, April 2011 for
consistent guidance and deadlines by requiring
comprehensive compliance follow-up by the State
agency receiving the CAP-SSSE funds and
enforcement by the FEMA Regional office and
FEMA Headquarters. Also see G.13, O.10, and
R.14.
b. “in coastal zones, or everywhere” is awkward.
Consider simply “in Special Flood Hazard Areas”
b. Honeycutt: This should not be limited to coastal.
b. Need to specify the level of inspection –
inside/outside? It is doubtful that an inside
inspection will be allowable.
There are many areas of the country where this is
just not an issue.
F.12. Revise NFIP regulations to prohibit
unmitigated fill anywhere in the SFHA 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.
With regard to F.12, local regulatory (should)
consider items such as “compensating volume” to
regulate floodway. Engineering practice requires
stormwater consideration for fill, so issues pointed
out in ASFPM NFPPR regarding flooding due to fill
should be addressed in this manner. Regarding
F.13. Incentivize revisions to the NFIP regulations
to prohibit septic systems in A or V zones and
floodways.
There were some comments to not allow septic
systems in A zones, but that may be an over reach.
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 of the proposal.
NFPPR Combined comm rec and comments
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F.14.a. Revise the NFIP regulations to prohibit the
use of fill for triggering Letters of Map Change and
changes in flood insurance rating.
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. a. Revise the NFIP regulations to require the
local ordinance to require that the local floodplain
administrator or building official is responsible to
determine substantial damage.
F.15.(b) In cases of emergency the person
responsible for determining substantial damage
may be expanded to include those individuals
under the direction of the local floodplain
administrator or the building official
Local floodplain administrator or building official
The cost of engineering fees and FEMA LOMC
review fees are already disincentives for filling in
floodplain and performing LOMC’s. Instead
prohibiting use of LOMC’s with fill, require
compensatory floodplain storage by the property
owner as part of the LOMC process. Many
communities already require compensatory
floodplain storage as a requirement of that fill. If a
small portion of a property floodplain is filled, but
an even larger portion of floodplain flood volume
is cut to add flood volume, the hydraulic effect of
the LOMC can actually have a beneficial floodplain
impact.
F.14, am adamantly opposed to not allowing fill to
mitigate for flooding where no erosion is expected
– if the floodplain is compensated for as indicated
above.
There appears to be a general movement toward
not using science and engineering because of
failures in management and enforcement – this is
not reasonable and should not be promoted by
ASFPM.
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.16. Revise the NFIP regulations to require
cumulative substantial improvement over the life
of the structure. see R.8
FEMA may consider a time frame such as a 10-year
period to track cumulative substantial
improvement (CSI). CRS credit could still be
provided for a lower threshold percentage that
50% value of the structure (LSI) or tracking CSI > 10
years, including for the life of the structure.
F.17. Revise the NFIP regulations to require
Comment received: if they need to be more
NFPPR Combined comm rec and comments
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buildings in coastal A Zones to be designed and
constructed to V zone standards to be more
resistant to coastal flood forces
resistant, the design and construction standards
need to be updated to achieve this
Need to define this terminology. If waves, that is
currently addressed with V zone designation.
Honeycutt: This is duplicative (or at least overlaps)
with several other recs in the document around
redefinition of the V Zone, LiMWA
mapping/mgmt., and one verbatim with this
concept (F22). Some members noted concern
with this type of mandate, preferring flexibility to
mitigate risk via floodplain mgmt. requirements for
coastal A zones. Not suggesting ASFPM abandon
this rec, but just make sure whatever appears in
the document is consistent across sections.
F.18 Revise the NFIP regulations to map and
regulate an erosion zone with rolling building
setbacks and require all NFIP communities to
adopt that standard. 44 CFR 60.1(b). The
regulatory standard should incorporate likely
future conditions and reflect the expected useful
life of the building constructed or substantially
improved
Many CRS communities are non-compliant of
basic, minimum NFIP regulations for new
construction or substantial improvements of
residential structures, but still receive CRS points
and flood insurance reductions for mitigation
activities of pre-FIRM and noncompliant post-FIRM
structures. See F.10.
Define “rolling building setbacks”
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.
Will this be while we are mapping the nation’s
floodplains or after we initially map the nation’s
floodplains? How much more will this cost?
Should we add it to our Mapping the Nation
Report if it is not already there?
Allow NFIP communities to identify, map, and
communicate erosion hazard zones and risks by
federal, state, or local Zone E on FIRMs or separate
GIS layers (may be used for CRS credit) per 44 CFR
Parts 59.1, 60.5 and 60.24. Also see K.16.
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.
While many activities and points have been added
NFPPR Combined comm rec and comments
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to the current CRS manual, additional options or
approaches may be found within existing state or
local programs.
F.19 Revise the CLOMR and LOMR-F requirements
to require an Environmental Assessment of all
CLOMRs and LOMR-Fs to ensure endangered
species are not impacted.
This should not be a part of the NFIP. There is
already a requirement that all LOMRs comply with
the Endangered Species Act, but an EA is overkill
on most LOMRs
Also phrased “F.19 Revise the LOMC requirements
to require an Environmental Assessment or lessthorough alternative process for some subset of
LOMC to ensure endangered species are not
impacted.”
Delete this in its entirety. This is going beyond FP
management, extending into the environmental
realm. Many of us are not supporters of this
approach. Let EPA take this issue on.
Environmental Assessments are expensive and
often of little value to the property owner or
community preparing them for LOMC’s. They
should be prepared when required by law and not
in ALL cases. Other agencies such as the U.S. Fish
and Wildlife, Environmental Protection Agency etc.
should direct those requirements instead of NFIP
regulations.
Does this duplicate F 20?
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.
Clarify the development triggers to require a
LOMC. See F.9. 44 CFR 65.3.
Recommendation to delete completely.
F. 20 Establish NFIP regulations to ensure
Endangered Species Act (ESA) compliance with
development, CLOMR and LOMR-F and addresses
other structures with impacts on threatened and
endangered species and critical habitat.
Received some comments from committee that
these should not be part of the NFIP
This is going beyond FP management. Let EPA take
this issue on.
As written, this is somewhat over reaching.
F.21. Promote NAI based development standards
in the international green construction code And
the international construction code.
Duplicate of F.17 (x3)
Develop specific coastal A zone construction
standards instead of the current concept of overengineering a building (breakaway walls +
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National Flood Policy—ASFPM 2015 Recommendations
openings ) to meet the insurance rating
requirements. The wave loads / pile engineering
requirements are greater in areas with 3+ waves
and dune erosion than in areas with 1.5 foot
waves far up a tidal estuary away from exposed
shorelines. FEMA should develop specific building
standards for coastal A-Zones rather than lumping
all coastal A-Zones along with V-Zones. FEMA
should develop actual model code language for
coastal A-Zones.
Honeycutt: Needs to be made consistent with
revisions to A11, A21, L18.
Food for thought: ASFPM may wish to go ahead
with this, but recognize the membership is not
unanimous in their endorsement. Some have
expressed concern about adding this mandate –
either as a redefinition of V Zone to include coastal
A zones, or as this proposed imposition of V Zone
standards in coastal A zones. See comment
immediately below.
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.
F.23. Require the adoption of a cumulative
standard by all NFIP communities, especially for
those that are actively participating in the CRS
program.
Expand coastal A zone mapping to large inland
lakes that experience moderate wave action.
F.24. FEMA and HUD should clarify NFIP
compliance for Manufactured Homes (MFH).
FEMA can refer to 44 CFR 59.1 Definitions and 44
CFR 60.3(c)(6 & 12). HUD can refer to 24 CFR Parts
3285 and 3286. Per FEMA Regional offices, the
local community is responsible for NFIP
compliance of MFH so the State MFH agency
should send installers to the Local Authority
Having Jurisdiction (LAHJ) for NFIP permit and
compliance requirements per 24 CFR 3285.102
Installation of manufactured homes in flood
hazard areas.
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F.25. Revise the NFIP regulations to require
floodproofed buildings have approved
maintenance and operations plans on file as part
of the permit requirements as well as being
updated annually.
F.26. Revise the NFIP regulations to require all
flood openings to comply with the design and
testing requirements for engineered opening.
Standard ventilation vents, when installed as
flood openings, seldom meet the net open area
criteria, and often do not allow the automatic
entry and exit of floodwaters.
F.27. Revise the NFIP regulations to require
mandatory training for surveyors, engineers or
architects who are authorized by state law to
perform work (e.g., elevation certificates,
LOMCs, etc.) related to the NFIP, to obtain 4
hours of continuing education units, biannually.
F.28. [Require FEMA/NFIP to provide each LFA a
“after action” summary following all declared
Federal disasters as soon as possible following
the event. The After Action summary should
include all NFIP paid Claims (similar to the
Repetitive Loss List). The LFA should be required
to include a copy of paid NFIP flood claims data in
each building permit file where structures have
been determined not to be substantially
damaged. FEMA regional offices should perform a
CAV on each community in a Federal declared
disaster within one year following the event]
F.23. In areas where historic flooding or other
information indicates that the site is not
“reasonably safe from flooding” (example
downstream from a dam), require assessment of
flood hazards for new development and
substantial improvements in these areas (outside
of the existing mapped SFHA) and, at a minimum,
apply Approximate A Zone standards to these
areas.
NFPPR Combined comm rec and comments
Define reasonably safe from flooding
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