National Flood Policy—ASFPM 2015 Recommendations
Training and Outreach Committee Recommendations for:
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Section E: Data & Technology
Section Q: Partnerships & Incentives
Section R: Federal Leadership
Section S: Building State & Local Capability
Section T: Individual Accountability
Section V: Climate Change
Section X: Resilience
Overall T&O comments:
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A few of the recommendations say who should be doing the implanting (such as “FEMA
should” or “States should” – or, in one case, “ASFPM should”) but most of the
recommendations are left without a recommended implementer. I don’t know if this is
purposeful, but for consistency, consider adding an implementer to all or deleting them
from the few that have them.
We did not go through and do any grammatical/editing changes. However, the TO
Committee leads are willing to help with that once the next iteration of the document is
ready.
Though we were not specifically assigned Section A, we have included below several
comments related to that section, as flood maps are a way to communicate flood risk
and this is of interest to us. A few comments are also included for Section B.
We deleted any section for which we had no comments.
Thank you for allowing us to assist in this effort. We learned a lot just going through all
the recommendations and considering each in turn.
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A. Flood Mapping
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A.1. Depict failure zones associated with dams, levees, diversions, and reservoirs on maps; where
mapped mandate regulatory action, insurance and mitigation. When zone D is used to depict
“Undetermined hazard” associated with Structural project, require flood insurance Also see G.1.
A.2. Account for geologic/geomorphic hazards on flood maps, including fluvial erosion /channel
migration zones. Channel migration zones have key relevance to endangered and threatened species
habitat requirements, e.g. salmonids, as well as building safety.
A.3. Include all coastal hazards (erosion, subsidence, sea level rise, storm surge) on flood maps, using a
150 years-into-the-future standard. These should be based on current medium to high GHC scenarios.
Current estimate of average U.S. residential structure life is 150 years. Also see L.3
A.4. Include special hazards in producing FISs and on FIRMs (stream mitigation zones, ice jams, flash
floods, closed lake basins, debris flow, alluvial fan etc.) Also see M.1, N.1, N.2
A.5. Map and designate properties with repeat flood damage claims and adjacent areas with repeat
flooding histories (including flooding from stormwater) as floodplain, for regulation and insurance Effort
should be made to identify and map not only specific “repetitive loss” properties, but also other adjacent
areas with documented, repeat-flooding histories, whether or not they technically meet NFIP repetitive
loss or severe repetitive loss definitions. NFIP should institute a surcharge for every claim or so, similar to
auto insurance. Repetitive loss properties can serve as key locations for investigations on “repetitive loss
areas.” Also see G.10
A.6. Allow non-regulatory products or other simplified processes to be used as a better way to assign
flood risk for insurance purposes, either through separate map or other means, then use flood maps for
regulation/planning/management
A.7.(a) Fully fund and implement National Flood Mapping Program (NFMP) as directed by Congress in
the 2012 NFIP Reform
A.7. (b) Fund map maintenance and regular map updating as continuation of the National Flood
Mapping Program and Risk Map
A.8. Continue to fund flood mapping & maintenance outside of NFIP policy and fee budget to the full
authorized BW-12 levels ($499 million/year).
A.9. Utilize and implement the appropriate recommendations of the new Technical Mapping Advisory
Council; Consider establishing TMAC as a long-term or permanent council
A.10. Revise the NFIP requirements to require or provide incentives (e.g. CRS) for communities to
establish GIS layers for subsidence (as part of the 100 year standard)
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A.11. (a) Produce coastal bathymetric maps and integrate with coastal topographic maps to produce
maps depicting storm surge, increased water surface elevations, reach of flooding in coastal A Zones—
Multi agency effort. Also see L.17
A.11 (b) Map and change the V-Zone standard from 3’ breaking wave to 1.5 foot waves in 1-percent
chance event as supported by FEMA research and analysis.. Depict V-Zones and Coastal A Zones based
on future conditions and best available science and data; require NFIP regulations and insurance to
reflect this standard
A.12. (a) Delegate authority and funding for mapping of all coastal and riverine hazards on NFIP flood
maps to qualified states under the Cooperating Technical Partners program.
A.12. (b) Require CTP delegated states to develop and maintain an archival system for all flood map
models for data stewardship and storage. Encourage and incentivize all states to archive flood map
data.
A.12.(c) As an alternative to the current mapping program, and for sustainability of the program, FEMA
could focus its attention to completing and maintaining a fully digital national flood hazard layer (rather
than trying to maintain flood “maps”) and leave the updating, maintenance, and stewardship/
management of topographic data, base maps, political boundaries, or other data layers of interest to
other federal and state agencies. A “map”, suitable for each purpose (such as flood insurance, floodplain
development management, zoning, etc.), can then be assembled by each local state or entity and
printed on demand; incentives will be needed for this to happen
A.13. Increase use of CTPs for delineating all coastal and riverine hazards on maps
A.14. Delegate authority to review LOMRs to qualified states and state designated local authorities,
with local review/sign off as needed Also see S.4
A.15. Produce all flood maps in geospatial data format & allow all such data as a substitute for
traditional paper products ; require LOMRs to be in the same geospatial format, including updated
databases
A.16. Map floodplains to the upstream source Also see G.2, T.8
A 17. Make past flood maps readily available in digital, electronically-transmittable format
A 18.(a) Map floodways based on no cumulative flood rise and no adverse impact on other properties
A.18. (b) In performing flood studies where the levee is assumed to contain the 1% chance flood, use the
top of the levee or landward toe of the levee as the landward edge of the floodway.
A.19. Map floodways based upon a combination of depth and velocity of the water to show the true
hazard and risk to property owners and communities; include as a standard NFIP flood map product
A.20. Map floodways using unsteady flow models to account for the loss of storage
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A.21. LiMWAs should not be optional and should be used on all coastal maps.
A.22. V-Zones should be mapped on all the Great Lakes where the modeling shows that conditions meet
V-Zone definition requirements, as well as the special hazard of ice.
A.23. An informational layer should be provided to all communities downstream of a dam showing the
SFHA assuming the dam is removed.
A.24. Produce future conditions mapping that includes all scientific and planned projections of sea level
rise, increase in riverine rainfall, watershed changes, etc.
A. 25. Revise and update flood flow calculation guidance in bulletin 17 B to reflect the
recommendations to the Subcommittee on Hydrology to produce updated Guidelines for Determining
Flood Flow Frequency titled Bulletin 17 C.
A. 26. Flood maps or associated non-regulatory products should communicate risk to the public in a way
the public can understand. For instance, the maps could convey an area of risk to life safety during the
1% annual chance flood based on the areas where flood water depth and flow could sweep someone off
their feet.
A27. An effort should be made to communicate the risk represented by the return period of a flood as
the areas where a flood is likely within the anticipated lifetime of a building or mortgage.
A28. FEMA should delete the rounded, whole-foot elevations from the BFE lines (“squiggly lines”) on the
FIRM. While it is understood that the BFE lines are included to show water flow and assist the user and
may be beneficial, there is no need to include the whole-foot BFEs with the BFE lines now that BFEs to
the nearest tenth of a foot are listed on cross sections on new maps. The rounded BFEs only serve to
confuse the user in an already complicated process to obtain a BFE at a property or structure for
insurance and regulatory purposes.
A29. Federal agencies producing hazard and risk-identifying products to communities, citizens, insurers,
etc., should keep the end-user in mind when designing such products.
B. Hydrology & Hydraulics
B.1. (a) Account for flood depths and velocities in setting zones and insurance rates; new charts or tools
should be provided to insurance agents to streamline rate selection, relates to A.19
B.1. (b) Provide flood depth grids as part of the FEMA flood map series and require communities to
adopt those maps for administering the NFIP requirements in their community
B.2. Automate data inputs and update regression equations using updated geospatial land cover and
gage data.
B.3. Use Doppler rainfall data more effectively in flood flow predictions
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B.4. (a) Incorporate future-conditions hydrology and cumulative impacts into flood risk determinations
under the NFIP Flood insurance studies should identify assumptions for hydrologic estimates, especially
for future conditions; adjust planning and regulation to avoid transferring the responsibility from those
that cause the problem to those that suffer the consequences.
B.4.(b) Ensure that the cumulative impacts of encroachments be incorporated into all flood risk
determinations such that there is no resulting increase in flood elevations without associated mitigation
actions
B.5. Fund and issue updates of National Weather Service regional rainfall frequency curves
B.6. (a) Develop engineering models that are properly calibrated to historic flood events to reduce the
uncertainty associated with the model results before such models can be deemed validated. .
B.6. (b) FEMA needs to establish guidelines and quality assurance protocols for evaluating the unsteady
and two-dimensional models, reporting requirements appropriate for these modeling techniques, and
for the development and review of floodway boundaries derived from such models.
B.7. Ensure that engineering models are open source, public, user-friendly, and widely accepted
B.8. Calculations of flood flow frequencies should be determined based upon a 95% confidence level to
reduce the uncertainty in associated flows used for flood risk determinations.
B.9 Use the 1% chance flood plus future conditions and freeboard for mapping and regulation
E. Data & Technology
E.1. Provide reliable funds for streamgaging and identify additional funding sources for streamflow data
gathering and analysis. Establish an intergovernmental commission for recommendations to meet these
goals. With increasing evidence of changes in climate and rainfall patterns, the enhancement and
strengthening of the nation’s stream gaging network and stream flow data collection is becoming critical
for flood risk management and long-range emergency and watershed planning and standard setting.
Also phrased: “Provide funds for streamgaging. Fully fund the NSIP and provide frequent updates of
stated regression equations.”
Also phrased: “Provide federal and over funds for streamgages.”
E.2. Fund and update and maintain list of critical index stream gages (NSIP) nationwide—federal funding
of this network is essential.
E.3. Develop mechanisms by which NWS/local warning systems can supplement stream gage data
E.4. Place all data collected post-disaster (including NFIP claims information) in public domain and easily
accessible to states, localities, researchers & stakeholders; in real time Comment: the claim of “privacy”
of much NFIP individual and geographic area data and the consequent continual state of public
confusion over costs and trends for 45 years has substantially retarded necessary research and analysis
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to assist the improvement of many aspects of the NFIP and disaster program. A major policy shift is
needed in this area.
E.5. Develop open-source tools for post-flood damage estimation
E.6. (a)Collect nationwide data on number of floodprone structures, dams & levees, population at risk.
New law (BW-12) requires such data as well as other critical data to be both collected and incorporated
by FEMA into future flood insurance rate maps. TMAC can suggest means of collecting and incorporating
data, however, FEMA is required to carry out these requirements. Also see I.11
E.6. (b) The federal interagency group Mit FLG, in consultation with state and local partners should
discuss a continuing process and key roles in how to collect, aggregate, analyze and operationalize the
collection and use of such data in the NFIP, flood damage reduction, disaster assistance, and other
federal construction, development, planning, funding and technical assistance programs.
E.6.(c) Nationwide LiDAR is needed for the entire nation with flood mapping being one of the major uses
of that topographic data since updated, accurate topo data is needed with adequate modeling in order
to produce accurate flood maps. Funding sources can be a combination of different federal sources,
along with state and local sources in order to reduce duplication of effort
E.7. (a) Generate complete list of number and location of residual risk floodplain buildings and
infrastructure and levee-protected buildings and infrastructure nationwide by making community
participation in NFIP, CRS, disaster assistance, HMGP grants, approval of local hazard mitigation plans,
and the Corps of Engineers’ Rehabilitation and Inspection program, (P.L. 84-99) contingent on
community’s supplying and periodically updating that information
E. 7. (b) Collection of the data on residual risk structures and infrastructure could be eligible for cost
share funding from HUD, FEMA and other funding sources.
E.8. Establish nationwide database on disaster costs and the benefit/cost ratios of mitigation, organized
by stream reach or shoreline as designated by the National Hydrography Dataset or State or Regional
equivalent thereof. Track relative disaster costs and responsibilities by levels of government and sectors.
This data is needed because Federal costs for disasters are skyrocketing on a path which rivals the longterm unbudgeted imbalance in the U.S. social security system – potentially in trillions of dollars; average
federal share has risen recent decades from modest percentages to 70 percent in recent major disasters.
Data needed to better document costs, trends and values of mitigation. See Q 19
E.9. Determine the true cost of disasters by developing a mechanism to account for all the direct and
indirect costs of a flood disaster. Increasingly, it appears these cost may be 10 times greater then
current estimates.
Q. Partnerships & Incentives
Q.1. Provide incentives for the acceptance of responsibility for flood risk by citizens, states,
communities, private sector Also see R.1–13; S1–15; T.1–12
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Q.2. Amend Disaster Relief Act to apportion costs, responsibilities, and roles among federal, state, and
local governments and the public commensurate with risk (for example, a sliding cost share could be
used as an incentive).
Q.3. Create financial incentives for communities, such as: basing all federal flood-related assistance to
states and localities on a sliding cost-share: the more mitigation, the smaller the non-federal share;
nonstructural measures and those that retain/enhance natural systems should always get a larger
federal share
Q.4. Make receipt of any federal disaster assistance (public or private) contingent upon taking
mitigation measures and the purchase of insurance, regardless of flood zone.
Q.5. Make Public and individual Assistance and mitigation grant eligibility contingent on NFIP
participation and compliance and on maintaining flood insurance
Q.6. Award increased Public Assistance to communities that meet all existing or future national
standards for infrastructure
Q.7. Amend existing law so that communities would be allowed to bank mitigation expenditures as nonfederal share of next disaster
Q.8. Make all flood related mitigation funding (including levee and dam funds) contingent on having a
comprehensive mitigation plan that will support community resilience/sustainability.
Q.9. Support and fund incentives for sustainable uses of floodprone agricultural lands
Q.10. Reduce subsidized crop insurance and crop disaster assistance (which is a disincentive to wise use
of floodprone lands) and tie all such taxpayer support to producer conservation compliance.
Q.11. Use incentives to encourage alternative, sustainable crops
Q.12. Deny subsidized crop insurance and disaster payments to agricultural producers with repetitive
flood losses who do not accept offers of permanent easements or switch to alternative crops
Q.13. States should Join together in existing or form new mutual aid (emergency management
assistance) compacts
Q.14. Delegate (with monitoring) to qualified states the administration of flood mapping, HMGP, FMA,
CAP, and environmental reviews for mitigation projects
Q.15. Explore use of true delegation model to move responsibility for NFIP activities to states (mapping,
monitoring communities for compliance, technical assistance, training, etc.)
Q.16. Make CAP funding contingent upon the state’s provision of one fully funded professional full-time
position—a CFM in floodplain management
Q. 17. Encourage market-driven private-sector incentives for mitigation
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Q. 18. Federal agencies should encourage integration of certification programs for the International
Codes and for floodplain management (CFM)
Q. 19. Deny subsidized assistance for public infrastructure that would encourage development in flood
risk areas
Q.20. Prohibit the use of federal funds to build any infrastructure to serve currently undeveloped SFHA.
Q. 21.Reform the casualty loss deduction to better target the deduction as well as incentivize those that
have mitigated. For example, limits could be set as to the number of times a person could claim the
deduction without first mitigating as well as a means tested system to limit incomes of claimants.
Q. 22. Develop a hazard mitigation tax credit much like energy efficiency tax credits that are given to
property owners.
Q. 23. Allow for tax advantaged disaster savings accounts
Q. 24. Provide specific IRS guidance more broadly exempting cost effective mitigation assistance from
federal taxes. Currently only FEMA mitigation programs have a specific exemption.
R. Federal Leadership
R.1. Establish high-level coordinating mechanism for federal water resources policy
R.2. Establish a National Flood Risk Management Policy
R.3. Adopt a watershed-based, comprehensive approach for all federal water resources activities and
programs
R.4. Evaluate compliance with federal EO on floodplain management to ensure 500-year protection for
critical facilities; ensuring access to and fully operational facilities during 500-year flood; avoiding
floodplain when possible; using future conditions in decision-making; avoiding adverse impacts
R.5. Assign responsibility for oversight of EO 11988 compliance to somewhere in Administration
R.6. Require all federal agencies to issue new floodplain management EO guidance that reflects 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.
R.8. FEMA should Establish a work group to assess and implement recommendations of 2012 report on
“Rethinking the NFIP”
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R.9. ASFPM should analyze “Effective State Programs” to work with states to encourage states to move
beyond basic and toward model flood risk management programs
R.10. Provide full funding for flood risk management data gathering and development (GIS,
streamgaging, forecasting, mapping, Integrated Ocean Observing System, research)
R.11. Give FEMA Director discretionary authority (with input from localities and the state) to require
communities to use advisory maps and BFEs (It could be a requirement of CRS communities to use
advisory or preliminary maps as best available data.)
R.12. Support professional certification programs for floodplain managers, adjusters, agents, and
others; provide more insurance-related training via the NFIP Training Contractor.
R.13. Provide generous and reliable funding for federal programs that generate the most long-term
impact, i.e., technical assistance and state/local capability-buildings
R. 14. 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
R. 15. Provide adequate resources and opportunities for collaboration with state and local partners of
interagency coordination entities such as the Federal Interagency Floodplain Management Task Force
and MITigation Federal Leadership Group (MitFLG).
R. 16. Consider shifting to a national model that delegates floodplain management authority to states,
with incentives provided through ALL federal grants, disaster relief, etc.
R. 17. Support examinations of alternative paradigms for national flood policy and programs, including
governance, mapping, avoidance of flood risk areas and flood insurance
R. 18. Provide incentives to encourage states to issue and enforce effective executive orders on
floodplain management
R.19. Establish strong federal floodplain 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.
R. 20. Develop sustained state and local flood hazard mitigation grant programs that can complement
federal investments in hazard mitigation.
R. 21. Provide incentives (CRS, disaster relief and others) for all state and local managers to be CFMs.
R. 22. Pass 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.
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R. 23. FEMA should develop and implement a CAP-SSSE type program to assist states in building state
hazard mitigation capability. Program should include an agreed-upon plan between State government
and FEMA.
S. Building State & Local Capability
S.1. Support and provide incentives to states in efforts to encourage progressive state and local
programs and activities, including NAI approaches (explore allowing states and counties with land use
authority to participate in the CRS program)
S.2. Develop procedures and implement the “managing state” concept, as authorized by law.
S.3. Increase funding for federal programs that provide technical expertise that supports state
mitigation strategies and the production of mitigation grant applications
S.4. Encourage (or require as condition of CAP or grants) states and localities to conduct own
engineering reviews, LOMR and LOMA submissions, and integrate state dam and levee safety programs
with floodplain management Also see A.14
S.5. Redesign CAP and other delegation programs to emphasize building state and local capability
instead of simply buying state services
S. 6. Negotiate CAP participation individually with each state with each change of state administration,
and require governor-level commitment from state, using many forms of federal funding as an incentive
S.7. Same as above—change to: States need to upgrade their entire programs: regulations, intraagency coordination, policies on where state emergency management funds are spent, their mitigation
efforts, etc. There should be some minimum standards for state programs, which ASFPM should work
with states/feds to create and promote.
S.8. Allow states to allocate up to 50% of CAP funding to state-selected non NFIP, but effective flood
loss reduction activities (not projects). If states can verify the benefit of other actions, it could be cost
effective to the NFIP.
S.9. Tie CAP funding to NFIP and flood disaster reduction-related needs and add annual inflationindexed increases
S.10. Provide incentives and disincentives to encourage states to view CAP as auxiliary funding to state
floodplain management programs, not sole source Require one full time state funded position (CFM) to
receive any CAP funds.
S.11. Properly fund CRS verification program to improve consistency and ensure CRS credits are
properly earned or class rating reduced. Consider simplified and easily verified requirements for level 9
participation.
S.13. Publicize successful activities of CRS communities – why they are successful, how the activity
reduces risk and/or promotes sustainability and how they got it all done
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S.14. Develop, fund, and implement technical and financial support and other incentives for localities to
conduct its own management and mitigation programs
S.15. Provide incentives to encourage communities to integrate floodplain management with land use
and watershed conservation plans Require in HM Plans and for credit of flood plans in CRS.
S.16. Conduct independent reviews of state and local programs to determine effectiveness on a five year
cycle.
S.17 All FEMA Regions should annually host meeting/training with State NFIP coordinators and SHMOs
T. Individual Accountability
T.1. Continue to move to actuarially sound flood insurance rates over time for all buildings T.2.
Continue movement towards actuarial rates for pre-FIRM residences as per HFIAA; put them on the
same path as others if they have a loss
T.2. Continue movement towards actuarial rates for pre-FIRM residences as per HFIAA; put them on
the same path as others if they have a loss
T.3. Continue increasing insurance rates on repetitive loss structures; and move to full actuarial rates if
SRL owners refuse an offer of mitigation assistance
T.4. (a) Encourage private insurance programs if the flood mapping, management and mitigation
aspects can be accounted for
Encourage insurance and reinsurance industry to rate flood coverage as part of homeowners policies,
with incentives for appropriate mitigation actions
T.5. Base receipt and amount of disaster assistance to individuals on the extent to which they mitigated
and/or insured their flood risk
T.6. Establish procedure by which FEMA Director can require mitigation for a structure that has filed a
flood damage claim
T.7. Give preference for mitigation grants to individuals who use their flood insurance claim payment for
mitigation
T.8. Discontinue practice of waiving the flood insurance requirement after issuance of LOMR-Fs ; apply
risk-based rates instead. Also see F.5, G.2, K.13.
T.8 (b) Deny disaster assistance to any structure for which a LOMA has been issued.
T.9. Expand outreach to the public, adjusters, and insurance agents about repetitive losses and how ICC
can be a most effective tool to mitigate the flood risk and reduce insurance premiums
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T.10. Appropriate additional funding for public outreach on flood risk and insurance, especially for
communities with levees
T.11. Clearly communicate flood risk (e.g. policy renewal should show what actuarial rate would be as
well as current rate); uncertainty in forecasts, better terminology; awareness campaigns
T.12 Enhance the outreach capabilities of FEMA disaster, mitigation, insurance and mapping programs
to promote a better understanding of individual risk and options to deal with the risk.
T.13. Ensure actual cost of flood insurance is annually communicated clearly and directly to policy
holders, regardless of discounts or subsidies
T.14 - Develop a nationwide flood public education strategy that identifies key messages and
appropriate terminology.
V. Climate Change
V.1. Evaluate regional/local vulnerability of U.S. population centers to climate change impacts and
provide adaptation options
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
V.3. Require analysis of impacts & adaptations to climate in all mitigation planning.
V.4. Issue Executive Order to compel federal agency consideration of climate change impacts Also see
L.3
V.5. Revise federal agencies BCA methods to include projected impacts of climate change over the life
of the project.
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.
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.
X. Resilience
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In order for progress towards resilience to be measured, a national baseline assessment of resilience is
needed. As part of this assessment, measureable resilience indicators need to be identified with the
input of states, local governments, academia, and others.
NOTE: this is a suggested added area of policy. Feel free to suggest national flood policy that relates to
this. In the final document, we will likely pull items from the remainder of the list that may fit more
appropriately in the resilience category and move them here.
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