National Flood Policy—ASFPM 2015 Recommendations
C. Stormwater & Watershed Management
C.1. Emphasize integration of water quality
(stormwater, water supply, wastewater) and
quantity (flood risk reduction, life safety) programs
and foster holistic and No Adverse Impact
stormwater approaches at regional, state and local
levels
To Dave Carlton—on many of these we need to
decide who or what agency/program (s) should
perform or try to implement the rec--LL
Also phrased “Recommend or require holistic and
no adverse impact stormwater approaches at state
and local levels for the reduction of runoff for the
reduction of flood damage throughout
watersheds, and for the protection of water
quality and groundwater recharge.”
C.1(a) Emphasize and foster the integration of
water quality programs within all watershed
management approaches at state and local levels.
C.1. Emphasize and foster the integration of
water quality programs with in all watershed
management approaches at state and local levels
OTHER RECOMMENDATIONS:
C.1. Offer a national definition of watershed
management that encompasses the range of
watershed resources to be management and
protected and the importance of runoff
management. If we have one, we should insert it
here-LL
C.2. Consider both flooding and water quality in
all FEMA HMGP and Environmental Protection
Agency Section 319 demonstration projects
C.2. Recommend or require holistic natural
floodplain function and no adverse impact
watershed management approaches or
regulations at state and local levels. This should
be done for the reduction of runoff, for the
reduction of flood damage throughout
watersheds, and for the protection of water
quality and groundwater recharge.
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C.3. Through community planning (i.e. stormwater
master planning) require critical facilities to
consider and quantify both mapped flood risk, and
the potential for increased risk due to land use
changes and climate change by quantifying
watershed and stormwater runoff that affects
the site with respect to the design life of the
facility.
From Jennifer Gerbasi (Terrebone, LA):
Don’t we already look at pre and post stormwater
runoff as a practice for all permitted activities in
the floodplain? Is this to assess risk outside the
floodplain? Including climate change here if it is
not already folded into the mapping process
seems wise. The rest would seem to be in place.
C.4. Encourage/incentivize (CRS and other)
rainfall, runoff reduction and runoff infiltration,
low impact development and green infrastructure
techniques to reduce and manage flood flows and
runoff to help in protecting water quantity and
water quality.
From Jennifer Gerbasi (Terrebone, LA):
I would like to see more explicit focus on
infiltration and permeable surfaces rather than a
focus on moving water away from the land via
conveyance. Good direction that already has
some traction.??? LL it seems to do that
C.5 Apply and expand NFIP Community Rating
concept to allow EPA and FEMA to credit
community actions to reduce stormwater and
urban flooding risk and to improve water quality
and green infrastructure. Credits could come in
form of advantageous sliding cost-shares for
grants, disaster assistance, or other incentives.
C.6. Encourage watershed management that
prevents an increase in flood flows by new
development or redevelopment with attention to
the control of not only peak flows, but also the
volume of runoff and the timing of runoff.
Already incentives in CRS. (look up prior to
submission )
C.7. Wetland& wetland functions and other flood
storage areas inside and outside of the SFHA
should be preserved or increased to maintain or
reduce downstream increases in flood frequency
and heights.
This is the type of activity that could be awarded
CRS points in multijurisdictional plans. Recognizing
the interdependence of the jurisdictions and
protecting the assets of the upstream community
for the benefit of the downstream. This will also
outline the potential liability for changes that
might damage downstream investments or assets.
C.8. EPA, as part of MS4 permits should require
the control of the peak and volume of runoff to
the 1% event, or greater to prevent the erosion of
stream channels, pollution, and damage to
adjoining structures which creates more pollution.
Is there data that suggests that the recurrence of
25 year storms is such that it should be the design
minimum rather than 2 or 10? Should the
standard be different based on the rainfall history
and projections for the geographical area?
Also phrased “EPA, as part of MS4 permits should
require the control of the peak and volume of the
1% annual chance event, or greater, as warranted
Brown-- This is the disconnect between FEMA & EPA.
From a flood perspective, the 1% chance event is what
causes problems. From a water quality perspective, the
more recurrent events are of concern. There needs to
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by stream conditions / historical flood
characteristics, etc, to prevent the erosion of
stream channels, pollution, and damage to
adjoining structures which creates more pollution.
be an acknowledgement of the differences, but an
integration of their consideration and impacts. I
suggest a 2 year for the water quality and 100 year for
flooding, and integrate designs to address the tiered
approach.
C.9. Consider requiring building
setbacks/establishing river corridors or buffers
from all streams, lakes, ponds coasts and
wetlands with that area conserved or
reestablished in its natural state to maintain or
reduce flood and ecosystem damages and
preserve water quality. See also K.10, K.11 and
K.12
Deb Mills-Streams should have a required setback
regardless of the area adjacent being natural or
not. The stream is a natural environment and the
riparian habitat and environmental services should
not be disturbed or eliminated for the benefit of
the adjacent activity. Often we see grading right
to the apex of the bank and the subsequent failure
of the previously stable bank.
C.10. EPA guidelines for watershed management
plans should include the impacts of flooding and
the impacts of development and the hydrologic
regime and flood risk.
C.11. As a prerequisite for Class 4 CRS
communities must require all new development
and redevelopment to use LID techniques to the
maximum extent possible for each site to mitigate
their impact.
this could be considered an over-reach—no, CRS
and NFIP are volunteer
There may be some thoughtful and valuable
disagreement about the value of certain LID
techniques and their value to habitat or flood risk,
energy use, land use, etc., so I don’t know that I
would feel comfortable supporting this suggestion.
Why? Explain ……… What is the motivation here?
To make Class 4 and higher CRS communities
harder to achieve? Or are you wanting more
emphasis on use of LID techniques? This is way
too vague!
Refer to Washington State Dept of Ecology NPDES
Phase I permit. LID BMPs are not appropriate for
every situation, e.g. infiltrating at the top of a
steep slope
NOT SURE WHAT THIS IS, BUT SEEMS OUT-OFCHARACTER WITH OTHER POLICY
RECOMMENDATIONS (VERY SPECIFIC)
C.12 Identify where Federal spending can be
aligned to achieve improvements in stormwater
quality and quantity goals. See also C.4 & C.5
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Shouldn’t we have more to comment on Water
Quality than just stormwater management? Other
stressors on water quality includes:
•Development encroachment and loss of habitat ,
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•Invasive species
•Water chemistry alterations/ increasing acidity
•Thermal stress
•Flow alteration (not just stormwater alterations,
but also from ditching or alterations of wetlands,
withdrawals for drinking water or snowmaking,
•Land erosion
•Nutrient loading
•Pathogens and toxins
--CWA permits, WOUS
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