National Flood Policy—ASFPM 2015 Recommendations
ASFPM NFPPR 2015
C. Stormwater & Watershed Management 1-5-15
Recommendation
Explanation/rationale
Watershed Management
C.1. Promote watershed approaches
(a) “Recommend or require holistic and No Adverse
Impact stormwater approaches at state and local levels
for the reduction of runoff to reduce flood damage
throughout watersheds, and for the protection of water
quality and groundwater recharge.” {FEMA; EPA;
USACE, MitFLG]
(b) Emphasize and foster the integration of floodplain,
habitat, and water quality programs within all
watershed management approaches at state and local
levels.[States, EPA]
The goal of watershed management should be the
preservation of natural processes and existing habitat
while protecting/improving water quality, water for
beneficial uses, groundwater recharge and ensuring any
increase in future flood hazards is mitigated.
This may require modification of current watershed
planning guidelines from EPA to include current and
future flood hazard impacts.
(c) Consider both flood risk reduction and water quality The most effective local programs tend to be those that
benefits in all FEMA HMGP and EPA Section 319 and
address multiple issues, not single issue or single
Smart Growth and Resilience demonstration projects
agency programs.
[FEMA; EPA]
C. 2. States and EPA should require watershed
(stormwater) management that prevents an increase in
flood flows by new development or redevelopment
with attention to control of not only peak flows, but
also the volume of runoff and the timing of runoff for a
range of flows from a channel forming event to
moderate (100-year) flood event. [States, EPA]
C.3. Wetlands (including appropriate buffers) and other
flood storage areas inside and outside of the 1% chance
floodplain should be preserved to maintain or reduce
downstream increases in flood frequency and heights.
States and communities should not allow wetlands and
storage areas to be filled without appropriate
mitigation, including complete replacement of their
storage function. [USACE;FEMA; MitFLG, States]
Without the control of increased runoff (peak and
volume) of runoff from new development, the cost of
development is transferred from the developer to
property downstream. Several states mandate
matching the peak flow for one or more design events
for the pre- and post-development condition. It is
better to also control the volume of total runoff for a
range of events and use the natural condition for the
pre-developed state.
This type of activity is awarded CRS points in watershed
management plans, recognizing the interdependence
of the jurisdictions and protecting the assets of the
upstream community while avoiding increases in
flooding of the downstream community/properties.
This will also define the potential liability for changes
that might damage downstream investments or assets,
as would C4.
C.4. (a) “EPA, as part of MS4 permits should consider
requiring the control of the peak and volume of the 1%
annual chance event to prevent severe erosion of
Standards vary from 2-5 year for EPA and 1% chance or
100 year for FEMA. Because these standards are based
on the probability of an event, they reflect regional
NFPPR rec and rationale
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Section C Watershed/Stormwater
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National Flood Policy—ASFPM 2015 Recommendations
stream channels, pollution, and damage to adjoining
structures during flood events which creates more
pollution.
conditions and can still be uniform nationwide. For
example, a 2 year standard for the water quality event
and 100 year for flooding may be acceptable if designs
to address the tiered approach are utilized.
C.4.(b) EPA and FEMA should collaborate to address the
disconnect between water quality and quantity focus
that results in exacerbating current problems for one
while mitigating the other.
[EPA; FEMA]
This is needed to ensure that their programs
complement each other as much as possible.
C.5 Riparian buffers should be required as a condition
of all new development to protect water quality, flood
storage, ecosystem services and development outside
of the buffers. [States, MitFLG] – See K.3.
Buffers are one of the most effective means to protect
both water quality and habitat
C.6 EPA should consider extending the standards of the
Clean Water Act to all development greater than ½ acre
instead of the current 1 acre and to somehow address
agricultural practices. [EPA]
Small feeder streams are critical to downstream water
quality and natural ecosystem functions
NFIP support of effective Stormwater programs
C.7. As a prerequisite for a Class 4 rating, require CRS
communities to require all new development and
redevelopment to use LID techniques to the maximum
extent possible for each site to mitigate their adverse
impacts. [FEMA]
C.8. Encourage/incentivize (CRS and other) runoff
reduction through the use of infiltration, low impact
development and green infrastructure techniques to
reduce and manage flood flows and runoff to help in
protecting water quantity and water quality. [FEMA;
EPA; MitFLG]
NFPPR rec and rationale
This would put more emphasis on using LID “to the
maximum extent possible” by the most highly rated of
the CRS communities. This also means that developers
would use the techniques that are appropriate for their
community. This relates to floods by reducing
impervious surfaces and maintaining infiltration to
avoid increased flows due to development
This would give some focus on infiltration and
permeable surfaces rather than a focus on moving
water away from the land via conveyance.
Credits could also come in form of advantageous sliding
cost-shares for grants, disaster assistance, or other
incentives
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Section C Watershed/Stormwater
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