National Flood Policy—ASFPM 2015 Recommendations R. Federal Leadership R.1. Establish high-level coordinating mechanism for federal water resources policy SOUNDS LIKE R1-R3 OVERLAP. AS ASFPM CERTAINLY KNOWS, THIS LIST OF RECOMMENDATIONS IS WAY LONG, AND A MORE CONCISE LIST OF "ASKS" WOULD BE MORE EFFECTIVE R.2. Establish a National Flood Risk Management Policy to include a comprehensive National Flood Risk Management Program within the USACE. Honeycutt: How would this relate (or would it) to the Unified National Program? Or are you looking at something totally new/different? R.3. Adopt a watershed-based, comprehensive approach for all federal water resources activities and programs encourage this through existing programs that may have the same goals, such as the USACE Silver Jackets program. EPA and NRCS have been doing this since the 1990s. Who else are we targeting? 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 to both neighboring properties and natural floodplain function. GOOD POINTS, BUT NOT FOCUSED ON PRIMARY RECOMMENDATION HERE R.5. Assign responsibility for oversight of EO 11988 compliance to somewhere in Administration and enforce ==Should a try be made for a new EO on flood plain/flood risk management? I ask the question because we may get something less supportive of sound FPM than what we have.LB 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 NFPPR Combined comm rec and comments Page 1 of 4 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations and implement recommendations of 2012 report on “Rethinking the NFIP” 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, including an analysis of existing similar programs, such as the USACE Silver Jackets program. This seems strange in an ASFPM document? R.10. Provide full funding for flood risk management data gathering and development (GIS, streamgaging, forecasting, mapping, Integrated Ocean Observing System, research) Honeycutt: This should include tracking of flood loss data (see E9) Shouldn’t this move to D. Data? 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, ins adjusters, agents, and others; provide more insurance-related training via the NFIP Training Contractor. R.13. Provide sufficient and reliable funding for federal programs that generate the most longterm impact, i.e., technical assistance and state/local capability-buildings ==add implementation of nonstructural measures especially elevation [less than 15] if it is using future conditions with climate change impacts and of course relocation and buyout which are permanent flood risk reduction measures assuming that the relocation site is not in any flood plain; not just out of the commonly called flood plain; the 100 year 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 tie to DRA ==Be sure enforcement of this concept is present. Somehow we have to get Congress and the 94% educated that there is no more support for Congress to provide bailout funds post disaster for bad local land use decisions and noncompliance with NFIP. 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 NFPPR Combined comm rec and comments Page 2 of 4 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations Framework 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 or laws on floodplain management Question received: are the governors of all states authorized to issue executive orders? 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. 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. Environmental Defense Fund (EDF) has additional expertise and information about such tools and can provide assistance. R. 20. Proved federal leadership and support for building capability for sustained state and local flood hazard mitigation grant programs that can complement federal investments in hazard mitigation. Moved to H. 23.? Or x-ref? R. 21. Provide incentives (CRS, disaster relief and others) for all state and local FP 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. This is a state issue. The feds cannot dictate or authorize local/regional utilities – stormwater or otherwise. R. 23. FEMA should develop and implement a CAPSSSE type program to assist states in building state hazard mitigation capability. Program should Clarify flood risk is not a federal responsibility Doesn’t this already exist? NFPPR Combined comm rec and comments Page 3 of 4 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations include an agreed-upon plan between State government and FEMA. NFPPR Combined comm rec and comments Should this move to H. Page 4 of 4 draft 10 9-14