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 Page 1 of 13 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations (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? Page 2 of 13 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations 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. Page 3 of 13 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations 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 Page 4 of 13 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations 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 Page 5 of 13 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations 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 Page 6 of 13 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations 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 Page 7 of 13 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations 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 Page 8 of 13 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations 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 Page 9 of 13 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations 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 Page 10 of 13 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations 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 + NFPPR Combined comm rec and comments Page 11 of 13 draft 10 9-14 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. NFPPR Combined comm rec and comments Page 12 of 13 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations 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 Page 13 of 13 draft 10 9-14