National Flood Policy—ASFPM 2015 Recommendations M. Arid Regions M.1. Utilize the best available techniques to identify and quantify the risk of flooding, erosion and debris flow hazards in arid regions, including alluvial fans and post-wildfire conditions. Also see F.18 and N.1. M.2. (a Use new science and technology to update hydrologic and hydraulic methods or models for arid regions projects. Encourage the use of stochastic numerical models to better simulate location, extent, and depth of flooding in areas of flow path uncertainty. Also see A.4 M.2. (b) In the past , delineation techniques have failed to recognize flow path uncertainty in arid regions. This resulted in unintentionally reducing the extent of predicted Special Flood Hazard Areas and/or under predicting volumes and depths of flooding and debris. After major flood-disaster storm events cause erosion and new flow paths that change flood risks vertically and/or horizontally, provide a low-cost LOMC process for NFIP communities and to update FIRMs (44CFR Part 65). M.3.(c) Development should be discouraged in areas subject to flow path uncertainty, erosion and debris flow, in arid regions and other geographies M.3. Develop floodplain management techniques which address wildfire, flood and erosion cycle hazards experienced in the arid regions. Best management practices will vary as appropriate amongst the arid regions. Revise NFIP definitions, regulations, and elevation requirements and arid regions for existing Special Flood Hazard Area zones: approximate Zone A in shallow sheet flooding less than 1-foot deep, Zone AH in true ponding areas, and Zone AO where depth exceeds 3 feet, redefine or use Zone AE. Clarify the elevation and freeboard requirements above natural grade in approximate Zone A, with no BFE. Refer to 44CFR Parts 59.1, 60.3(b) and (c). NFPPR Combined comm rec and comments Is a the rec and b the comment? Don’t see where b is worded as rec—does it need to be? They seem like two diff issues Who? How? LL Really like this one—it is specific as to who, what and how Should it be the first rec in this section? Since it seems very overarching Page 1 of 2 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations M.4. FEMA should resume the needed arid regions research that was started with the 1985 DMA study and the 1996 National Academy study. A starting point for resuming this effort may include: • Review the effectiveness of present identification, characterization, and mapping guidelines in Appendix G. Identify pros and cons. • Collect alluvial fan flooding mitigation efforts utililized in the arid regions. Establish postconstruction performance of these features. Identify pros and cons. • Establish specific aspects of both Appendix G guidelines and mitigations efforts which need improvement and/or further research and development. • In light of recent improvements in modeling software, FEMA should resume the alluvial fan flooding research that was started with the 1985 DMA (“DMA” needs identification at first instance?) study and the 1996 National Academy study. This effort should establish clear guidance and policy on the applicability of different software on active and inactive alluvial fan flooding areas, and establish different classifications if necessary and appropriate. • Establish policy and guidance to ensure that new technology used to determine flood hazards is not improperly used to allow development in areas where high risk alluvial fan flooding is possible. • Coordinate with the Army Corps of Engineers to develop guidance on the appropriate application of two dimensional software (including theirs) on alluvial fans and areas of unpredictable flow paths. This would produce defensible recommendations by an organization with no conflicting interests in the determination. NFPPR Combined comm rec and comments Page 2 of 2 draft 10 9-14