National Flood Policy—ASFPM 2015 Recommendations
Q. Partnerships & Incentives
Recommendation
Explanation/rationale
Q.2. Congress should amend the Disaster Relief Act
to apportion costs, responsibilities, and roles
among federal, state, local governments, and the
public commensurate with risk (for example, a
sliding cost share could be used as an incentive for
state and local governments; to reward them for
actions that reduce flood risk). The same type of
incentive could be provided in the flood insurance
policy for actions by property owners that reduce
flood risk and claims to their building. Also see R.1–
13; S1–15; T.1–12 [Congress]
Q.4. Make receipt of any federal disaster assistance
from flooding (public or private) contingent upon
taking appropriate mitigation measures and the
purchase of flood insurance, regardless of flood
zone. [MitFLG—FEMA]
Create financial incentives for communities, such
as: basing all federal flood-related assistance to
states and localities on a sliding cost-share: the
more mitigation, the smaller the non-federal
share; nonstructural measures and those that
retain/enhance natural systems should always get
a larger federal share. A set formula, based on
savings to the federal taxpayer would be
established so state and local governments can
calculate their return on investment.
Move to Dis mgt Sect O
Continually using federal taxpayer monies to pay
again and again for damages to the same building
of infrastructure without requiring flood
insurance or cost effective mitigation to break the
cycle is not good public policy
Q.5. Make Public Assistance (PA) grant eligibility
contingent on NFIP participation and compliance
HMA eligibility is contingent on NFIP
and on maintaining flood insurance or proof of
participation.
state or community self-insurance [FEMA/Congress]
PA is not
Q.7. Amend existing law so that communities
would be allowed to bank mitigation expenditures
as non-federal share of next disaster [Congress]
The mitigation measures would have to meet
existing BCA and other requirements
Q.8. Make all flood related mitigation funding from
any federal agency (including levee and dam funds)
contingent on having a local comprehensive flood
mitigation plan that will lead to community
resilience/sustainability. [MitFLG; Congress]
The first important step in reducing risk a
community must do is to identify and assess its
risk. Once that is done, actions post or predisaster can be addressed without having to deal
with the planning in an emergency.
Q.9. Support and fund incentives for sustainable
uses of floodprone agricultural lands-[USDA/EPA]
Q.10. Explore the impacts of modifying how flood
losses are covered in the Multiple Peril Crop
insurance to incentivize appropriate and
sustainable ag and land uses within floodplain
lands and to minimize the chance that farmed
These can range from sustainable crops to
permanent floodplain easements.
There is a delicate balance between avoiding
residential and commercial development in
floodplains and allowing suitable and sustainable
agricultural use of flood prone lands while
ensuring the continued use of flood prone lands
NFPPR policy rec and explanations
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National Flood Policy—ASFPM 2015 Recommendations
floodplain land is not converted to
residential/commercial development. Continue to
tie all such taxpayer support to producer
conservation compliance as well as compliance with
all applicable federal and state regulations. [USDA]
to provide natural functions that reduce flood
losses and provide multiple ecosystem benefits.
Q.13. Modify EMAC (Emergency Mgt Assistance
Compact) to ensure mutual aid is available for hard
hit communities to obtain assistance for substantial
damage and rebuilding permit assistance.
[Congress; FEMA]
EMAC covers response but does not cover critical
mutual aid assistance for communities to make
substantial damage assessments or issue permits
for hundreds or thousands of building in the post
disaster and immediate recovery stage.
Q.14. Delegate (with monitoring) to qualified states
the administration of flood mapping, HMGP, FMA,
CAP, and environmental reviews for mitigation
projects Also see H [FEMA]
This is necessary to eliminate duplication of effort
and to provide knowledgeable localized expertise
that will streamline and speed up mapping,
mitigation and assistance to communities.
Q.15. Explore use of true delegation model to move
responsibility for NFIP activities to qualified states
(mapping, monitoring communities for compliance,
technical assistance, training, etc.)
Move to S or not?
Q.16. Make CAP funding contingent upon the
state’s provision of one fully funded professional
full-time position in floodplain management—who
should be a CFM (Certified Floodplain Manager)
[FEMA]
Other agencies, such as EPA and DOT fully
delegate programs to qualified states; then the
federal agency monitors and evaluates the work
by the state to determine if the delegation should
continue.
Exceptions could be made only if the state can
demonstrate it is spending and equivalent or
greater amount of funding for state staff on other
actions that FEMA agrees reduce flood risk
Q. 17. Encourage market-driven private-sector
incentives for mitigation [MitFLG; Congress]
This can be done with building codes recognized
by private insurance carriers or other means
R. 20. Provide incentives (CRS, disaster relief and
other grants) for all state and local FP managers to
be CFMs.
[FEMA; USACE;NOAA; HUD]
Agree is this should move here, not R
Q. 19. Federal agencies should
encourage/incentivize integration of certification
programs for the International Codes and for
floodplain management (CFM) {FEMA; HSS]
Local floodplain managers had limited training
and status prior to the Certified Floodplain
Manager program. Having that trained program
at the local level helps communities make better
flood risk decisions to support community
resilience
Too often local building officials and the permit
officials who issue floodplain permits are stove
piped at the state and local level, whereas close
collaboration saves money and time.
Q. 20. Deny subsidized assistance for public
infrastructure that would encourage development
in currently undeveloped flood risk areas [MitFLGUSACE; OMB; FEMA]
Current guidance for USACE projects, such as
levees supposedly have this condition, although
there have been projects that violate those
provisions.
NFPPR policy rec and explanations
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R. 22. Create incentives in federal programs (CRS,
disaster relief, grants, etc) to States that develop
and enact sufficient enabling authority for regions
and communities to develop stormwater utilities or
similar mechanisms that can provide tools,
assistance and resources for an array of flood risk
management and loss reduction actions.
[MitFLG; Administration; FEMA: USACE; EPA;]
Too many states recreate the federal stove pipes
for programs dealing with water quantity and
water quality, and that is a barrier to effective
management of both. The federal government
cannot dictate this, but can provide incentives or
make it a condition of grants, etc.
Q. 22.Reform the casualty loss deduction to better
target the deduction as well as incentivize
mitigation. For example, limits could be set as to
the number of times a person could claim the
deduction without first mitigating as well as a
means tested system to target claimants who truly
need assistance. [Congress]
The casualty loss deduction for flooding costs
taxpayers lots of money(add $), with much of it
going to higher income property owners in very
high value building in high risk areas such as
coastal areas. The concept here is to remove
incentives for people to build in these high risk
areas where they can externalize their cost to the
taxpayers.
The concept is to provide a means where a
property owner can save for or get a tax credit for
actions that mitigate their hazard risk. As flood
insurance rates move toward full risk rates,
property owners can easily determine their
return on investment for such actions.
If a community or state provides mitigation
funding that meets the federal BCA standards to
reduce future taxpayer costs that grant funding
should be exempt from federal taxes.
Q. 23. Develop a hazard mitigation tax credit much
like energy efficiency tax credits that are given to
property owners. Additionally or alternatively,
allow for tax advantaged disaster savings accounts
[Congress]
Q. 24. Provide specific IRS guidance more broadly
exempting cost effective mitigation assistance and
funding from federal taxes. Currently only FEMA
mitigation programs have a specific tax exemption
in federal law. [Congress]
NFPPR policy rec and explanations
Agree to put here, not R
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