National Flood Policy—ASFPM 2015 Recommendations
R. Federal Leadership
Recommendation
Flood Policy Coordination, Oversight and Funding
R-1 DEVELOP AND IMPLEMENT A FEDERAL FLOOD RISK
MANAGEMENT STANDARD (FFRMS)
a) Establish a National Flood Risk Management Standard
(FFRMS) that is used by all federal agencies for grants
and assistance; following the guidance in the Unified
National Program for Floodplain Management.
b) All Federal disaster assistance and federal grants for
any purpose should be contingent on compliance with
a federal Flood Risk Management Standard (FFRMS)
that ensures any federally assisted construction or
reconstruction has reduced/no future flood risk, thus
saving federal taxpayers the cost of repeatedly paying
for the same disaster costs.
See: O-6, F-4, F-8, S-2, J-2, J-3, H-4, H-11
[MitFLG, CEQ, NSC]
R-2 Require all federal agencies to issue updated guidance
on EO 11988 (Floodplain Management) and assign an
oversight agency to evaluate all agency(s) compliance with
that federal EO. This guidance must ensure 500-year
protection for critical facilities; ensuring access to and fully
operational critical facilities during 500-year flood; avoiding
floodplain unless no alternative exists; using future
conditions in decision-making; avoiding adverse impacts to
both neighboring properties and natural floodplain
function.
Explanation/rationale
A federal FFRMS was in place following Hurricane Sandy in
the Northeast U.S. in 2012, which had to be met in
reconstruction in order to access federal funding. Such a
standard protects the federal taxpayer investment in
construction and re-construction so this taxpayer funding is
not repeated over and over.
There are some pieces of this in various documents like
Executive Orders 11988, 11990, and the EOs on Resilience
and climate adaptation, but a comprehensive standard
needs to pull it all together.
Agencies guidance on this EO is now decades old and must
now reflect new law and other EO’s on resilience,
sustainability and climate change, with stronger
mechanisms for monitoring, reporting, enforcement and
accountability; (Example; Require that all Federally funded
transportation projects incorporate comprehensive flood
and storm hazard mitigation design standards.
See: O-6, F-9, J-2, H-4, H-12
[Administration, CEQ, OMB, MitFLG]
R-3 Provide sufficient and reliable funding for federal
programs that encourage use of future conditions and
resilience and generate long-term impact on reduction of
flood losses and lead to resilient communities, i.e.,
technical assistance and state/local capability-buildings.
Implementation of nonstructural measures, which result in
permanent flood risk reduction measures especially
relocation and buyout (this a taxpayer one and done).
Building elevation [if less than 15’] is another preferred
measure.
See: S-4, H-9, H-11
[Administration, Congress]
R-4 Establish and fund a high-level federal coordinating
mechanism for federal water resources policy to not only
coordinate federal policy, but to cut through the stove
pipes when federal agencies deliver programs/services to
state and community partners.
Since the demise of Water Resources Council (WRC), there
is no coordinating mechanism for federal water resource
policy. Some claim Congress does that, but various aspects
of water policy are stove piped in a number of Congressional
Committees with limited coordination.
See: C-4
[Administration, Congress jointly]
NFPPR policy rec and explanations
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National Flood Policy—ASFPM 2015 Recommendations
R-5 Provide adequate resources and opportunities for These entities are now performing interagency coordination
federal interagency coordination entities to collaborate among the federal family, but are not yet reaching out to
with state and local partners.
State and local government partners who implement these
programs at the ground level.
[Administration, Congress, MitFLG, FIFM-TF, all agencies]
R-6 Provide federal leadership and support for building A number of states have floodplain management programs
capability for sustained state and local flood risk stronger than the NFIP, and some have state mitigation
management and mitigation programs and funding that can funds that can match FEMA mitigation funds, or standcomplement federal investments in hazard mitigation.
alone state funded mitigation.
See: Section S and H-2, H-5
[MitFLG, FEMA, USACE, EPA, NOAA]
R-7 STRENTGHTENING FEMA
FEMA continues to have issues related to being part of DHS
a) Restore FEMA to independent agency status to allow – from the DHS “tax” to needing to conform with broader
greater flexibility in achieving their mission objectives. DHS other programs. In the post-disaster environment, this
complicates and delays programs like HMGP and does not
b) Ensure that flood loss reduction concerns are allow FEMA to be nimble.
addressed throughout the national planning
frameworks including the National Response The national level frameworks that exist today are
Framework and National Mitigation Framework.
collectively called the National Planning Frameworks.
c) Ensure FEMA Director has/uses discretionary authority This could also be covered with a federal Flood Risk
(with input from localities and the state) to require Management Standard (FRMS) developed by MitFLG and
communities to use advisory maps and Advisory BFEs outlined in R-1.
post disaster. (It could also be a requirement for CRS
communities to use advisory or preliminary maps as
best available data.)
See: O-5
[FEMA, MitFLG]
Adjusting Existing Federal Programs
R-8 FEMA should Establish a work group to assess and Some of these recommendations will require FEMA to
implement recommendations of their 2012 report on develop recommendations, costs and pros and cons and ask
“Rethinking the NFIP.”
Congress to pass legislation.
See: F-1, H-16
[FEMA, state and local partners]
R-9 Remove any impediments to USACE performing Some District offices say the requirement that sponsors
nonstructural projects.
must do land acquisition prevents them from doing
Acquisition/relocation projects.
See: I-3, P-2, O-6
[USACE, MitFLG, CEQ]
R-10 Develop and implement effective monitoring, FEMA has been lax in ensuring communities and states are
probation and suspension guidance and standards to properly monitored, placed on probation and suspended
improve NFIP compliance for community and state from the NIFP when failing to meet their obligations under
participation.
the NFIP.
[FEMA, states]
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R-11 Deny federal assistance or cost sharing for public Current guidance for USACE projects, such as levees
infrastructure that would encourage development in supposedly have this condition, although there have been a
currently undeveloped flood risk areas.
number of projects that violate those provisions.
See: H-4
[MitFLG, USACE, OMB, FEMA]
R-12 Adopt a watershed-based, comprehensive approach EPA and NRCS have been doing this since the 1990s, but key
for all federal water resources activities and programs in agencies like USACE and FEMA struggle with this.
collaboration with the states. Encourage this through
existing programs that may have the same goals, such as
the USACE Silver Jackets program.
See: S-6, C-2
[Administration with CEQ lead]
R-13 Support professional certification programs for A number of those in the chain of decisions/advice to
floodplain managers, ins adjusters, agents, and others; property owners lack training in Flood insurance rates,
provide more insurance-related training via the NFIP maps and NFIP standards and regulations.
Training Contractor and states.
See: F-7, S-9, G-5
[FEMA, WYOs, Realtors, Home builders, states]
R-14 Enforce all lease restrictions on federally leased The law supposedly does not allow flood insurance on
floodprone land, especially denial of flood insurance, and Federally leased flood prone land, or renewal of such leases.
non-renewal after expiration of the lease.
Both provisions have been violated by either Congress or the
agency(s).
See: H-16
[GSA, USACE, FEMA, NPS, OMB]
Consideration of New Federal Approaches
R-15 Support examinations of alternative paradigms for This starts with admitting the current system of NFIP,
national flood policy and programs, including governance, disaster relief, water resources policy and other approaches
mapping, avoidance of flood risk areas and flood insurance to managing flood risk have not reduced flood damages or
disaster costs over the last 80 years, thus the need to
See: O-2,G-13, G-14, Q-8
explore alternatives.
[Administration, Congress, academia, NGOs]
R-16 Perform a study of shifting national flood risk This would require tying state’s effectiveness in managing
management to a national model that delegates floodplain flood risk to disaster relief, not to the availability of flood
management authority to states, with incentives provided insurance. It might also mean having no or little federally
through ALL federal grants, disaster relief, etc.
backed flood insurance, but leaving flood insurance to the
private insurance and re-insurance market.
See: O-2
R-17 PRIVATE SECTOR INVOLVEMENT/INVESTMENT
a) Involve/reward private sector investments and actions The private sector investment market has shown some
in managing flood risk by establishing strong federal interest, but it need clear rules showing its investment will
flood risk management rules that are based on the be protected from foreseeable changes that present a risk
principles of long term resiliency – including from to that investment; this would include assurances that
climate change, use of natural ecosystems for resilience for future conditions is addressed.
resilience/sustainability and flood damage reduction.
b) Explore the Federal government’s use of various These approaches would focus on maximizing natural
natural resource exchanges and markets, such as ecosystems that not only attenuate flooding naturally, but
NFPPR policy rec and explanations
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habitat exchanges, carbon markets and use of also address the issues that are identified as one of the
easements to riparian/wetland or coastal land owners. causes of increasing the intensity of rainfall and storms.
See: G-14, Q-8
NFPPR policy rec and explanations
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