Federal Leadership - The Association of State Floodplain Managers

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R. Federal Leadership
Recommendation
Explanation/rationale
R.2. Establish a National Flood Risk Management
Policy that is used by all federal agencies; following
the guidance in the Unified National Program for
Floodplain Management {MitFLG; CEQ]
There is some pieces of this in various documents
like EO 11988, 11990, and EO on Resilience and
climate adaptation, but a comprehensive document
needs to pull it all together
R.1. Establish and fund a high-level coordinating
mechanism for federal water resources policy
Since the demise of 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
Committees with limited coordination
R.3. Adopt a watershed-based, comprehensive
approach for all federal water resources activities
and programs in collaboration with the states.
Encourage this through existing programs that
may have the same goals, such as the USACE Silver
Jackets program. [Administration with CEQ lead]
EPA and NRCS have been doing this since the 1990s,
but key agencies like USACE and FEMA struggle with
this
R.4.Require all federal agencies to issue updated
guidance on EO 11988 on Floodplain Management
and Evaluate agency compliance with that federal
EO to ensure 500-year protection for critical
facilities; ensuring access to and fully operational
critical facilities during 500-year flood; avoiding
floodplain when possible; using future conditions
in decision-making; avoiding adverse impacts to
both neighboring properties and natural floodplain
function. [Administration; CEQ; OMB; MitFLG]
Agencies guidance on this EO is now decades old
and must now reflect 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.
R.7. Enforce all lease restrictions on federally
leased floodprone land, especially denial of flood
insurance, and non-renewal after expiration of the
lease. [GSA; USACE FEMA; NPS; OMB]
The law supposedly does not allow flood insurance
on Federally leased flood prone land, or renewal of
such leases. Both provisions have been violated by
either Congress or the agency(s).
R.8. FEMA should Establish a work group to assess
and implement recommendations of 2012 report
on “Rethinking the NFIP” [FEMA]
Some of these recommendations will require FEMA
to develop recommendations, costs and pros and
cons and ask Congress to pass legislation
NFPPR Combined comm rec and comments
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R.9. Give FEMA Director discretionary authority
(with input from localities and the state) to require
communities to use advisory maps and BFEs post
disaster. (It could also be a requirement of CRS
communities to use advisory or preliminary maps
as best available data.) [FEMA; MitFLG]
This could also be covered with a federal Flood Risk
Management Standard (FRMS) developed by MitFLG
R.10. Support professional certification programs
A number of those in the chain of decisions/advice
for floodplain managers, ins adjusters, agents, and to property owners lack training in Flood insurance
others; provide more insurance-related training via rates, maps and NFIP standards and regs
the NFIP Training Contractor. [FEMA-Mitigation]
R.11. 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 [Administration;
Congress]
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.
R. 12. Make NFIP participation and disaster
assistance contingent upon states’ ensuring that
their funding, regulations, and programs comply
with the NFIP; with monitoring and penalties for
noncompliance tied to Disaster cost share.
Educate the 94% of the population that does not
flood that they are paying the cost of those who
build and live at risk so they can express their
concerns to Congress on disaster bail outs.
R. 13. Provide adequate resources and
opportunities for federal collaboration with state
and local partners of interagency coordination
entities such as the Federal Interagency Floodplain
Management Task Force and Mitigation
Framework Leadership Group (MitFLG).
These entities are now performing interagency
coordination among the federal family, but are not
yet reaching out to State and local government
partners who implement these programs at the
ground level
R. 14. Perform a study of shifting national flood
risk management to a national model that
delegates floodplain management authority to
states, with incentives provided through ALL
federal grants, disaster relief, etc.
This would require tying state’s effectiveness in
managing flood risk to disaster relief, not to the
availability of flood insurance. It might also mean
not have federally backed flood insurance, but
leaving flood insurance to the private insurance and
re-insurance market
This starts with admitting the current system of
NFIP, disaster relief, water resources policy and
other approaches to managing flood risk have not
reduced flood damages or disaster costs over the
last 80 years, this the need to explore alternatives
Question received: are the governors of all states
authorized to issue executive orders?
R. 15. Support examinations of alternative
paradigms for national flood policy and programs,
including governance, mapping, avoidance of flood
risk areas and flood insurance
R. 16. Provide incentives to encourage states to
issue and enforce effective executive orders or
NFPPR Combined comm rec and comments
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Federal leadership R---clean draft 11-5-14
laws on floodplain management
Move to incentives? Q
R.17. Establish strong federal flood risk
management rules for federal investments and
actions that are based on the principles of long
term resiliency – including from climate change,
use of natural ecosystems for
resilience/sustainability and flood damage
reduction. Explore the Federal government’s use
of various natural resource exchanges and
markets, such as habitat exchanges, carbon
markets and use of easements to riparian/wetland
or coastal land owners.
R. 18. Proved federal leadership and support for
building capability for sustained state and local
flood risk management and mitigation programs
and funding that can complement federal
investments in hazard mitigation. [MitFLG; FEMA;
USACE; EPA; NOAA]
Also see Section S-State cap and H 23-Mit
R. 19. Provide incentives (CRS, disaster relief and
others) for all state and local FP managers to be
CFMs.
R. 20. 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 resources
for an array of flood risk management and loss
reduction actions.
[MitFLG; Administration; FEMA: USACE; EPA;]
This would focus on maximizing natural ecosystems
that not only attenuate flooding naturally, but also
address the issues that are identified as one of the
causes of increasing the intensity of rainfall and
storms.
A number of states have floodplain management
programs stronger than the NFIP, and some have
state mitigation funds that can match FEMA
mitigation funds, or stand-alone state funded
mitigation
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
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.
Move to mit or state cap
NFPPR Combined comm rec and comments
Page 3 of 3
Federal leadership R---clean draft 11-5-14
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