National Flood Policy—ASFPM 2015 Recommendations
V.
Climate Change
V.1. Evaluate regional/local vulnerability of U.S.
population centers to climate change impacts and
provide adaptation options, especially for
increased intensity or frequency of major storm
events
V.1.a Develop unified national policy/response
plan to deal with the impacts of climate change,
especially sea level rise, including mitigation prior
to an event and response after an event. Develop
minimum standards for the expenditure of all
federal dollars following a disaster to account for
anticipated climate impacts.
V.2. Support/participate in data collection &
analysis on impacts of and adaptation to climate
change
Sounds like another non-reg product (see
comments on A1-5)
Where will the expertise for the evaluation come
from? Where will the funding for the adaptation
options come from?
Could this be the resilience index? LL
V.3. Require analysis of impacts & adaptations to
climate in all mitigation planning.
Honeycutt: This should apply to more than just
mitigation planning. Why so narrow a focus?
V.4. Issue Executive Order to compel federal
agency consideration of climate change impacts,
or alternatively, support existing Federal
requirements, recommendations or mandates that
has Federal agencies integrating climate change
considerations into their policies and procedures.
Also see L.3
EO already exists in large part—sustainability and
resilience Eos
reserve executive orders for national emergencies
where swift, decisive action is needed to avoid
catastrophe. Climate change is not new, only the
hype and general recognition of climate change.
Climate change considerations are already part of
many agencies' considerations under the category
of best available science and data.
Change to implement through F-S-L coop
V.5. Revise federal agencies BCA methods to
include projected impacts of climate change over
the life of the project. As info becomes available
Is this covered in P?
NFPPR Combined comm rec and comments
This exists… 13514, 13653, President’s Climate
Action Plan, impending Federal Flood Risk
Management Standard policy. Is there something
specifically missing from these that require
direction via an EO (vs. other implementing
vehicle)? If so, call that out here.
Honeycutt: Which agencies? As noted in another
comment (W8), USACE has already implemented
SLR for coastal planning/projects.
One issue with this is that it assumes we have data
needed to know what climate will do to flood risks
in inland watershed – we don’t, certainly not on a
national basis that would allow consistent
application in BCAs. It may be premature to
recommend this until we have more/better data
on which to base climate-influenced flood hazard
data for use in BCAs.
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National Flood Policy—ASFPM 2015 Recommendations
V.6. Develop grant guidance to
encourage/incentivize projects to address climate
change
V.7. Require all Class 7 and better CRS
communities to consider and plan for climate
change in their floodplain management plans,
maps and regulations using available data
Better yet, require that ALL CRS communities
“consider and plan for climate change in their
floodplain management plans, maps and
regulations”; States should and could lead the
way!
Why Class 7 and above. Why not make it a
category to earn points. There are places where
Climate Change isn’t going to be an issue, so why
penalize them? Add it to the CRS catalogue.
V.8 Require all Class 4 and better CRS
communities to include the impacts of land use
and climate changes through 2100 in their
mapping, planning, and regulations.
NFPPR Combined comm rec and comments
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 proper land use and climate change
impacts / adaptation? This is way too vague!
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