National Flood Policy—ASFPM 2015 Recommendations
H. Mitigation & Risk Reduction
Recommendation
Mitigation Planning
1. Incentivize states and communities to develop
more holistic mitigation plans that increase
resilience and sustainability of their economy.
Include items like: infrastructure mitigation,
ongoing educational programs, post-disaster plan
effectiveness/lessons learned, and capability
assessment without federal funding.
Explanation/Rationale
This would improve plan quality and effectiveness at
increasing resilience. This also adds important resilience
elements to plans which are currently missing or under
developed.
2. Implement a community natural hazard resilience
score (flood) and tie it onto the mitigation
planning process.
This would give communities and states a better
indication of how their decisions impact resilience over
time. A score would also add long term focus to the
plans which should be looking to at least the year 2100.
3. Require entities receiving Public Assistance
funding to repair and reconstruct damaged
infrastructure, create a mitigation plan for each
system receiving funding. The plan should
require:
a) mitigation measures in plan be implemented
within a 10 year period
b) demonstration of a reduction in future
damage of at least 50%
c) the mitigation accounts for future conditions
during the infrastructure systems expected
life
This begins to reduce future damage and federal
assistance to infrastructure systems. Prepared entities
would implement mitigation as part of recovery. Others
would need to figure out how to finance and implement
mitigation measures over time.
Future federal assistance should be severely limited
without this mitigation plan and implementation.
MITIGATION GRANTS
4. Expand state capability for continual mitigation
by:
a) Extending delegation of oversight of HMGP,
FMA, and PDM to all qualified states.
b) Developing a FEMA/State partnership
program for mitigation modeled on the CAP.
This addresses issue of state capability to routinely
implement mitigation. It moves the delegation pilot
program into implementation and will result in expedited
mitigation. Initial pilot programs can be established
through the USACE Silver Jackets program.
5. Change date for inclusion of eligible project costs
This would allow potential grant project costs to start
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under HMGP to the date of disaster declaration.
immediately after the declaration date if states and
communities choose to provide up-front funding.
Encourages disaster reserve funding.
6. Advocate changes to HMA mitigation projects
and options:
a) Ensure HMA grant funding is never diverted
away from traditional minor “non-structural”
mitigation projects to flood major flood
control projects.
b) Push for FEMA to recognize dry flood
proofing of residential structures which can
reduce flood damage and flood risk.
c) Broaden eligible mitigation options to include
other retrofitting measures that reduce flood
losses. Provide technical information and
financial incentives to encourage their
adoption.
This improves mitigation options and ensures major
flood control projects don’t lessen funding to desired
non-structural mitigation.
7.
This increases post-disaster mitigation funding and
rewards states that have opted to create an Enhanced
All-Hazards Mitigation Plan. Could offset by reducing for
communities following minimum codes.
Incentivize state and locals with sliding scale for
cost share in mitigation programs like HMGP.
Consider:
a) Standard mitigation plans at 15% HMGP and
enhanced mitigation plans at 20% HMGP.
b) Higher cost share assistance to states and
communities that meet and go beyond the
International Building Codes and NFIP
regulations
ICC-INCREASED COST OF COMPLIANCE MITIGATION
7. Alter focus of HMGP for flood disasters to focus
primarily on mitigation for uninsured owners that
have no other mitigation options. Funnel a
portion of initial HMGP funds into the NFIP’s ICC
program for insured homeowners & communities
(via assignment of claim) to mitigate.
This partially addresses lack of timeliness of current
HMGP, saves large administrative cost of HMGP, and
further encourages purchase of flood insurance
8. Produce and release an annual ICC report on
funds expended, mitigation implemented, and
reserve balance.
This ensures the ICC program can be monitored to access
its effective utilization as an important federal mitigation
program.
9. Update eligible costs under ICC. Fully allow costs
associated with acquisition and relocation
projects. Restrict eligibility for ICC elevation to
heights less than 15 feet. Adjust policy fee
accordingly to accommodate change.
This would address the issue of ICC incentivizing only
elevation (in potentially hazardous areas) because it’s
the fastest post-flood mitigation. Allows properties to be
quickly purchased at full market value and the land
converted to open-space.
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10. Increase maximum of ICC coverage ($50k or
more) and allow a sliding scale to account for
regional cost variation and inflation. Adjust policy
fee accordingly to accommodate change and/or
allow the insured to purchase additional blocks of
ICC coverage up to the limit of their policy or
value of their home.
This helps addresses issues within ICC program related to
mitigation costs and lack of adequate funding for
homeowners to mitigate in varying situations and
locations. It also potentially increases ICC revenue.
11. Expand ICC triggers. Insured should be able to
Increases accessibility to ICC funds for mitigation at
trigger ICC with other means such as Rep Loss and points in time where is most desired and cost-effective.
Severe Rep Loss status, substantial
improvements, Floodplain map zone or BFE
changes etc.
NON-FEMA MITIGATION PROGRAMS
12. Incentivize sustained state and locally funded
flood hazard mitigation programs that can
complement federal investments in hazard
mitigation.
This spreads the responsibility for mitigation (which is
directly related to public safety and economic resilience)
to states and locals.
13. Expand “environmental” benefits for nonstructural mitigation beyond the FEMA programs
and BCA module (Corps, etc)
This could allow for non-structural mitigation funding in
locations where state or local jurisdictions have mapped
and are regulating other flood hazards (riverine erosion,
mudslides, ice jams, etc.).
14. Increase funding for existing Corps nonstructural
programs and remove prohibition to evaluate
nonstructural alternatives to compare to
structural unless requested by the non-federal
project sponsor/owner from PL 84-99 program.
The permanent authorization for the Corps already
exists. This would address two major impediments to
Corps considering non-structural mitigation.
MITIGATION -DISASTER ASSISTANCE & RECOVERY
15. Create additional mitigation funding options by
advocating for:
a) A new low cost loan program (or leverage an
existing one like HUD, SBA, etc.), to ensure all
homeowners and small business owners have
access to mitigation funds which can be paid
back over time.
b) Advocate for a full suite of non-FEMA
federally-declared disaster recovery funding
programs (HUD, USDA, SBA and others) to
provide consistent/steady mitigation funding
nationwide.
This help addresses gaps in current mitigation options
and stabilizes some of the post-disaster mitigation funds.
Owners who desire mitigation, and willing to pay for it
(typically because the Return on Investment is positive),
but doesn’t have the financial resources to pay up front.
Institutionalizing non-FEMA mitigation programs
(through Stafford Act amendments) would 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.
16. Deploy non-structural mitigation workshops in
This would institutionalize floodproofing workshops that
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disaster areas during the initial recovery phase
and focus homeowner mitigation techniques and
on natural floodplain function benefits.
were done after Sandy. But get them there within weeks
of the event.
17. Communities must participate in NFIP to get flood
mitigation and associated flood disaster
assistance.
X-ref to Mapping A. 100 (maps expire). This also
addresses the issue of communities growing with no
standards and getting federal dollars to recover.
18. Improve use of Public Assistance 406 Mitigation
Program and associated field deployment of postdisaster mitigation programs by:
a) Require mitigation training/certification for
FEMA staff and contractors that are field
deployed FCOs, PA and IA field staff.
b) Develop metrics through reportable tool
demonstrating that every PA Public
Worksheet has been fully evaluated for
mitigation eligible opportunities.
This helps to increase mitigation under PA and IA
programs through training and reporting. It should help
allow states and locals to implement hazard mitigation
plan actions as part of the recovery process.
MITIGATION TOOLS & DATA
19. 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.
20. Continue to improve FEMA BCA module. Use real
in-time discount rates, update depth-damage
functions, include a module for erosion/landslide
risk (ie. houses at the edge of a river bank or
slope), etc.
This expands on the past BCA improvements FEMA has
made. The desire is to make the BCA module reflect
reality by accounting for mitigation benefits.
21. Develop a web-based tool which allows users to
compare the costs of various “mitigation options”
and compare to the associated short and long
term costs. The tool should account for things
like implementation costs, estimated insurance
costs/savings, IAHP grants, and EHP issues so that
owners are provided.
This will help provide return on investment calculations
for mitigation. It will streamline and institutionalize
methods for delivering mitigation assistance. It also will
encourage market-driven private-sector incentives for
mitigation. If homeowners (and governments) have ALL
the facts (short and long term) they can make informed
choices.
22. Increase partner accessibility to real-time GISbased claims data for use by state and local
officials in mitigation planning, recovery, and
implementation.
This addresses issue of partners not having real-time
access to damage data that can aid in mitigation.
23. Review disaster and mitigation programs by:
These items provide a means of learning lessons from
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a) Periodically (3-5 years) conduct an
independent evaluation of mitigation
programs including PDM, HMGP, FMA to
quantify their cost effectiveness in reducing
losses.
b) Expand FEMA’s Building Sciences postdisaster Materials Assessment Teams work to
more disasters from multiple hazards to
increase knowledge of mitigation
performance measures.
MITIGATION RULES & REGS
24. Modify historic building exemption to ensure
utilities within the exemption are protected
through BFE/DFE requirements or some other
method.
NFPPR Rec and rationale
mitigation. It would also provide some oversight of
programs and potentially stave off some program cuts.
This would eliminate future insurance claims and
disaster assistance to utilities in historic buildings.
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