National Flood Policy—ASFPM 2015 Recommendations
H. Mitigation—to CB--should we add to this title?
H.1. Encourage states and communities through
incentives to develop holistic mitigation plans that
will contribute to community resilience and
sustainability of their economy while integrating
multiple federal programs with a comprehensive
review process
H..
Also phrased “Produce and release an annual ICC
report on funds expended, mitigation
implemented, and reserve balance Research
incorporating elevation dollars at the actual cost
for the community (similar to establishing a per
diem rate) not an across-the-baord flat rate.”
Combined from H-26
FEMA’s Hazard Mitigation Program is not working. It
should be discontinued and replaced by diverting the
grant funds to the insurance fund and used for buyouts. It takes too long before the funds for buy-outs or
elevation are available under the grant programs. By
the time they are available most victims have moved on
to other solutions, often rebuilding ‘in place.’
CB—We seem to have no HMGP specific rec, so I
put this comment here-it is “overarching”
FEMA has data bases that can identify ICC usage.
We need to ask ourselves how this information
could be used and what benefit it gives before
adding it to a FEMA wish list. If they already have
it, no extra effort to share it
H.3. Expand ICC to allow assignment of claim to
fully cover the acquisition costs of severely
damaged and destroyed buildings as a means of
compliance , if the damaged structure is then
destroyed or rebuilt in compliance.
??
H.4. Increase maximum of ICC coverage to
$50,000 with an inflation factor and adjust policy
fee as necessary for costs; allow ICC claims over
$50,000 by creating a sliding scale for necessary
geographies to reflect market mitigation costs that
requires match funding or other mechanisms that
ensure cost control
We need better language for this statement, it’s
full intent is clear – esp. on sliding scale.
H.5. Implement law that allows FEMA Director to
impose use of ICC when beneficial to NFIP Fund
and relax triggers for eligibility requirements of ICC
claim eligibility so more structures can qualify (RL,
SRL, etc.) see G 11
As with G- 11 I struck this as ICC is available to any
structure that qualifies. I’ve seen it used absent a
federal declaration but local events caused
substantial damage. I’ve left the comments in
because the various points of view are interesting.
ICC caps should be eliminated and structures that are
substantially damaged purchased at full market value
and the land converted to open-space. Owners should
have no choice – accept the buy out or fund the repairs
at their expense.
Duplicates G11—which section should it go?
H.6. Expand incorporation of ecosystem services
and credits in benefit-cost analyses in all agencies
methods for non-structural mitigation including
open space and land use approaches that reduce
NFPPR Combined comm rec and comments
This is supposedly included in the new BCA
module—only for FEMA.
Acknowledge and allow for mitigation funding in
Page 1 of 7
draft 10 9-14
National Flood Policy—ASFPM 2015 Recommendations
flood damages
H7. Establish permanent authorization for US
Army Corps of Engineers to conduct nonstructural
floodproofing projects; increase funding for
existing Corps nonstructural programs
H.8. Continue to update FEMA B/C procedures to
update depth-damage functions and include all
social and ecosystem services benefits
H.9. Streamline and institutionalize methods for
delivering mitigation assistance and funding after
flood disasters through development of a
mitigation options tool which can be delivered to
impacted property owners to lay out mitigation
options (and financial impacts) . Such a tool would
inform mitigation decision and HMA grant
participation. It needs to include real-time
insurance benefits, IAHP grants, and EHP issues so
that owners are provided. This conversation can’t
be complete without a discussion about having
timely information about insurance benefits for
the determinations of substantial damage, permit
needs, and to give the owners the best variety of
opportunities for mitigation appropriate to their
situation.
H. 10.(a) Train FCOs, PA and IA field staff to
require post-disaster mitigation and incorporate
into all-hazards mitigation plans and post-disaster
response and recovery programs.
NFPPR Combined comm rec and comments
locations where State or local jurisdictions have
mapped and are regulating other flood hazards
(riverine erosion, mudslides, ice jams, etc.)
If there are no barriers, suggest deleting this
statement. auth needed
Buss: ==The permanent authorization for the Corps
already exists. More funding is needed as well as
including in the benefits ALL of the benefits of
nonstructural. OMRRR of nonstructural and
structural must be adequately determined cost
wise in the decision making process as to what
project to build-structural or nonstructural. In the
Corps PL 84-99 program, the prohibition of the
Corps to even evaluate nonstructural alternatives
to compare to structural unless requested by the
non federal project sponsor/owner must be
removed. As it has been, the project
sponsor/owner in PL 84-99 will only ask for
nonstructural to be evaluated if the Corps cannot
economically justify a structural project. This is
rare in Corps economics.
Same thing as H.6. I think the BCA module needs
improvements, like using the real in-time discount
rates, a module for landslide risk (not just from
wildfire but houses at the edge of a river bank or
slope), etc.
Such as…
a. Require? The local governments, whether prior
to or after a storm, are focused on recovery to get
back into business, AND mitigation to avoid the
damages in the future. PA often focuses on
Page 2 of 7
draft 10 9-14
National Flood Policy—ASFPM 2015 Recommendations
H. 10.(b)Ensure that PA staff and contractors
have expertise to make decisions about postdisaster reconstruction of public infrastructure
and facilities that incorporate mitigation through
complete application of all work eligible through
Stafford Act Section 406 Public Assistance Hazard
Mitigation. Measure metrics through reportable
tool demonstrating that every PA Public
Worksheet has been fully evaluated for
mitigation eligible opportunities.
replacement to the status quo, not mitigation
which would increase safety. Generally, we are
fighting to be allowed to implement our hazard
mitigation plan and pursue “improved projects” to
leverage the PA funds and HMGP to achieve the
better result.
b. Moved from O. 15
H.10.( c ) Develop necessary training and tools to
ensure full use of Public Assistance 406
Mitigation Program to repair/place damaged
public infrastructure in a more resilient manner.
H.11. Continue to advocate for HMGP base
funding at 15% of eligible federal disaster recovery
costs; with 20% HMGP funding for states with
FEMA approved enhanced mitigation plans.
PLEASE INCLUDE SOME BRIEF EXPLANATION OF
"ENHANCED"
H.12. Write rules to implement HFIAA, BW-12,
DMA2000 provisions for severe repetitive losses,
delegation of HMGP, and ICC
Separate these out and make more specific. Make
sure each is necessary. SRL has been done,
delegation of HMGP has been piloted in10 states
(1 per Region).
H.13. Track all repetitive loss information in
databases to identify location of building and
cause of flooding, and share information with state
and local partners on a real time basis. See E 4
This already exists and is available to states.
“Cause,” because this lifts from insurance
information, is date of event, states can usually
track to a major storm event. Deleted as we have
it. Not sure this is fully the case
Also phrased “Track all repetitive loss information
in databases to identify location of building and
cause of flooding, and share information with state
and local partners on a real time basis. See E 4.
Provide LFA with digital mapping (location) of all
Repetitive Loss, Severe Repetitive Loss and single
paid claim properties using caution that this
personal information is protected by the Privacy
Act. Encourage or require that the community’s
mitigation plan identify mitigation actions to
mitigate flood risks to these properties.”
H.14. Fully expand the state management
oversight pilot policy program to all eligible states
for administrative oversight of HMGP, FMA, and
PDM.
NFPPR Combined comm rec and comments
Isn’t FEMA doing this with the Pilot Program?
Should we check on full implementation intent of
FEMA before we include this? Simply expand to
qualified states--
Page 3 of 7
draft 10 9-14
National Flood Policy—ASFPM 2015 Recommendations
H.15. Change date for inclusion of eligible costs
under HMGP to the date of disaster declaration.
Does this mean grant project costs could start at
declaration date, not post grant obligation and
grant agreement paperwork? If that’s what is
meant, specify. Otherwise, delete as it doesn’t
make sense
H.16.(a) Periodically (3-5 years) conduct an
independent evaluation of mitigation programs
including PDM, HMGP, FMA to quantify their cost
effectiveness in reducing losses. . Give mitigation
grant funding priority to communities that have
successfully mitigated Repetitive Loss and Severe
Repetitive Loss properties
NEMA provides an annual document to Congress
highlighting the projects undertaken in states from
the previous year’s funding cycle which has helped
stave off some program cuts. Perhaps ASFPM
could undertake for mitigation?
H.16.(b) Expand FEMA’s Building Sciences postdisaster Materials Assessment Teams work to
more disasters from multiple hazards to increase
knowledge of mitigation performance measures.
H.17. Evaluate mitigation plans of communities hit
by a disaster and summarize lessons learned and
evaluate effectiveness of mitigation plans.
H.18. Require state and local mitigation plans to
incorporate consideration of cost-effective
infrastructure mitigation investments to increase
community resiliency.
H.19. Cross-train code officials and floodplain
managers in building code-flood loss reduction
programs. Certify CFM’s as qualified floodplain
inspectors, so State can include them among and
license them as building inspectors for floodplain
purposes. See H 32
In Florida, there aren’t any provisions for CFMs to
become licensed inspectors absent an extensive
construction background. Such certification
would ease transition to inspector status.
Currently, a CFM must be accompanied by a
licensed Building Inspector, who likely isn’t well
versed in floodplain compliance.
H.20. Increase cost share assistance to states and
communities that meet and go beyond the
International Building Codes and NFIP regulations:
an alternate; Reduce disaster and mitigation
funding for states and communities that follow
only the minimal International Building Codes &
NFIP regulations.
Comment Received: should not penalize
communities for meeting the minimal – should
increase the requirements so that the minimum is
at an acceptable level
H.21. Build state capability for mitigation by
Initial pilot programs can be established through
NFPPR Combined comm rec and comments
Alternatively, create an incentive for higher
standards by prioritizing communities taking
additional steps for HMA grant funding.
Page 4 of 7
draft 10 9-14
National Flood Policy—ASFPM 2015 Recommendations
developing a FEMA/State partnership program for
mitigation modeled on the CAP.
the USACE Silver Jackets program.
H.23. Firmly clarify eligibility for “structural” flood
control projects using FEMA HMA grant programs
to ensure that traditional “non-structural” projects
are funded in lieu of structural projects eligible for
US Army Corps of Engineers or USDA Natural
Resource Conservation Service funds.
In light of Major/minor this needs careful wording
24. Promote dissemination of success stories
(such as those on FEMA.gov); emphasize
mitigation effects on flood insurance premiums.
24. FEMA does this from Joint Field Offices – a
large compendium of Mitigation Success Stories is
on FEMA.gov. Suggest we delete.
H. 25. Require state and local hazard mitigation
plans include emergency action plans and consider
adverse impacts on other properties and
communities Also see I.9
Perhaps an ASFPM role here
This is not appropriate. Many states include State
HMPs as addendums to Large, single State
Emergency Operations Plans but as written this is
not appropriate.
H. 26. Encourage states and communities to
develop holistic mitigation plans that will
contribute to community resilience and
sustainability of their economy while integrating
multiple federal programs with a comprehensive
review process
Also phrased “Encourage states and communities
to develop holistic mitigation plans that will
contribute to community resilience and
sustainability of their economy while integrating
multiple federal programs with a comprehensive
review process through the Silver Jackets program,
or develop a tiered LHMP system that requires a
higher level of planning and integration the larger
the community. Alternatively, create incentives
through HMA/CRS for communities to have a
higher level of HMP integration.”
H. 28. Establish online database of state and local
mitigation projects organized by type of mitigation
NFPPR Combined comm rec and comments
=Push for FEMA to recognize dry flood proofing of
residential structures which can reduce flood
damage and flood risk.
==Develop a broad selection of mitigation
approaches; more than acquisition, elevation, and
small drainage projects. Include other retrofitting
measures on the menu of measures that can
reduce flood losses and provide technical
information and financial incentives to encourage
their adoption.
2ND HALF OF THIS SENTENCE NOT CLEAR. WHAT
KIND OF REVIEW IS SUGGESTED? RELATED TO
RESILIENCE AND SUSTAINABILITY, OR SOMETHING
DIFFERENT?
This needs to include an effective, ongoing
educational program .
==These plans must focus on the long term
objective of having the community/state move to
no flood risk as much as feasible possible. Any
short term objectives must meet this long term
objective. Plans should be looking to at least the
year 2100.
Agreed. States have access and can provide
community-specific downloads, but communities
Page 5 of 7
draft 10 9-14
National Flood Policy—ASFPM 2015 Recommendations
project
should be tracking their own mitigation actions.
This is why we’ve deleted.
H.29. Increase emphasis in state and local
mitigation plans to state and local
capabilities/programs and what they can and will
do, without federal funding.
H.29. Require a high-level federal interagency
(MitFLG?) follow-up review of causes, costs,
impacts, policies, and mitigation response for all
major Presidentially-declared disasters.
I don’t understand objection on right? This is
intended to mirror NSTB post plane crash reports
FEMA’s on-line archive of Success Stories does
this. Maybe what we need are some links to these
things, like on our mitigation committee website.
Capability analysis and description of all available
programs is a requirement of state and local
HMPs. I changed this to a softer, more accurate
statement. as long as we promote building state
capability
I PERSONALLY DISAGREE STRONGLY WITH THIS
RECOMMENDATION. DISASTER PREPAREDNESS
AND RELIEF ARE FUNDED FROM FEDERAL
SOURCES; WHY SHOULD MITIGATION BE VALUED
AND PRIORITIZED LOWER? ASFPM OF ALL GROUPS
SHOULD ADOPT THE OPPOSITE PHILOSOPHY
One example could be a revolving loan fund that is
established through the HMGP or other program.
H.30. (a)Create (or utilize existing programs in
HUD, SBA, etc.) low cost loan mechanisms to
ensure all homeowners and small business owners
have access to mitigation funds which can be
spread over time
H 39 (b) Advocate for steady HUD, USDA, SBA and
other mitigation funding through Stafford Act
amendments to prevent uneven federal financial
disaster recovery support due to sequestration or
lack of will to fund programs such as Community
Development Block Grant – DR or USDA
Emergency Watershed Protection Programs.
Federally-declared disaster recovery funding
should not be dependant upon the political power
of senators and representatives from the impacted
region.
H.31.Deploy nonstructural mitigation workshops in
disaster areas during the initial recovery phase
right after the disaster
Also phrased “H.31.Deploy nonstructural
mitigation workshops in disaster areas during the
initial recovery phase and focus on natural
floodplain function benefits. “
H.32. Certify CFMs as qualified floodplain
NFPPR Combined comm rec and comments
From Scott Fraser: In Florida, there aren’t any
Page 6 of 7
draft 10 9-14
National Flood Policy—ASFPM 2015 Recommendations
inspectors, so State can include them among and
license them as building inspectors for floodplain
purposes. See H 19
provisions for CFMs to become licensed inspectors
absent an extensive construction background.
Such certification would ease transition to
inspector status. Currently, a CFM must be
accompanied by a licensed Building Inspector, who
likely isn’t well versed in floodplain compliance.
H.33. Modify historic building exemption so as
not to include utilities within the exemption, so
electrical boxes, air conditioners etc. must meet
BFE/DFE requirements.
From Scott Fraser: No need to continually have
these utilities & A/C units ruined when Substantial
Improvement can allow building to remain below
BFE but require elevation of attending services.
H.34. Allow the insured to purchase additional
30k blocks of ICC coverage, over and above the
standard 30k that is included in the SFP, to a limit
of 150k worth of ICC .
H 34and H35 added by Mitigation Committee
respondent. These may belong in an NFIP section.
H.35. For compliance reasons, allow ICC funds to
be accessed by an insured whose structure has
been remapped from an A zone into a Coastal A
or V zone.
H. 36. Encourage market-driven private-sector
incentives for mitigation
From Q.17.
H.37. Develop sustained state and local flood
hazard mitigation grant programs that can
complement federal investments in hazard
mitigation .
From R.30
H.38. Develop open-source tools for post-flood
damage estimation to better inform post-disaster
mitigation strategies for program/technical
assistance/grant targeting, BCA support data, and
review and improvement of local risk reduction
policies.
NFPPR Combined comm rec and comments
Page 7 of 7
draft 10 9-14