A. ASFPM--NFPPR - FLOOD MAPPING
(Categorized by sub-topic) 12-23-14
Recommendation
Explanation/rationale
FLOOD MAP FUNDING and OVERSIGHT
1. (a) Fully fund and implement National Flood
Mapping Program (NFMP) as authorized by
Congress in the 2012 NFIP Reform (at $400
million/year budget from appropriated funds)
[Congress, FEMA]
Accurate Flood hazard area mapping is the backbone of
this nation’s flood resiliency and sustainability efforts.
Priority should be placed on enhancing the map
accuracy and completing the flood hazard mapping for
the entire nation. Refer to ASFPM 2013 “Flood
Mapping for the Nation” –link-- Report for an estimate
1. (b) Fully implement the National Flood Mapping of the extent of expected costs involved.
Program (NFMP) as authorized by Congress in the
2012 NFIP Reform [FEMA, Technical Mapping To avoid falling further behind in the flood mapping
and maintenance needs, annual funding at a substantial
Advisory Council (TMAC), CTPs, States]
level is needed.
2. Fund map maintenance and regular map Once developed, flood maps need to be continually
updating as continuation of the National Flood updated tom stay relevant. Once all 22,000
communities are mapped, policy fees should be able to
Mapping Program. [Congress, FEMA]
fund map maintenance
3. Capture, on an ongoing basis, unmet mapping
needs from the Map MOD and Risk MAP
scoping, discovery efforts, and input from state
and local partners in order to have and be able
to report to congress an accurate scope of
needed mapping efforts. These unmet mapping
needs should also be summarized by state and
county and provided to the Technical Mapping
Advisory Council (TMAC) for their information
and use [FEMA, states]
An accurate accounting of mapping needs, by state and
county, needs to be produced and shared with the
congress (as well as with TMAC) so that congress has a
clear understanding of the enormity of the task at hand
and can plan for a continuous funding stream needed
to fulfil the challenge
TMAC needs this information to get a handle on the
scope or their tasks
4. Utilize and implement the recommendations of When the 2014 TMAC recommendations are made
the 2014 Technical Mapping Advisory Council available, they will need to be funded and
(TMAC) [Congress, FEMA, other federal implemented.
agencies, states, local agencies]
5. The TMAC should become a permanent council Having TMAC as a permanent council would insure
congress’s access to an independent, informed body at
or advisory committee[Congress, FEMA]
any time when the need for such timely advise would
arise
ASFPM NFPPR rec and rationale
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6. Consider adding a $5 Transaction Fee to every
Flood Zone Determination performed as part of
the closing of every property, with the noted
Transaction Fee dedicated to flood mapping
and map maintenance (FEMA)
The transaction fee concept is something that FEMA
previously proposed as a way to help generate funds
for flood mapping and needs to be revisited. Some kind
of fees are needed so the users of the information help
pay the costs of obtaining the information.
REFINE MAPPING PROCESSES AND STANDARDS
7. (a) Provide periodic reports on the status of
valid map data (as reflected in the Coordinated
Needs Management Strategy (CNMS) data
base) including data on both modernized and
non-modernized map panels. Include in this
report information on metrics used to define
progress in updating engineering data as
recorded in the CNMS data base. [FEMA]
(b) Review and update the standards for
establishing valid map data to enable the
identification of map data that has been
appropriately calibrated against historic flood
events. [TMAC]
In order to better understand the progress in producing
accurate, up-to-date flood maps, periodic reports on
the status of valid map data (as reflected in the
Coordinated Needs Management Strategy (CNMS) data
base) that would include data on both modernized and
non-modernized map panels is needed.
Concerns have been raised by the home builders
association and others regarding the accuracy of
FEMA’s flood hazard data. Unless engineering studies
being conducted are calibrated against historic flood
events it is difficult to quantify the uncertainty of the
flood hazard data being generated.
It is standard protocol in mapping to include the date of
the source information used to develop the map.
(c) Flood hazard maps should include the date of
the engineering study in addition to the date of
publication. [TMAC]
8. Change the minimum standard for designating
floodways to the “full conveyance floodway”
concept and continue to allow no (0.0 feet)
impact for proposed encroachment into
floodway. A full conveyance floodway includes
all of the area inundated by the 1% annual
chance flood, except those shallow areas and
embayment into small drains and gullies where
water would be ponding but would not be
effectively convey flood waters.
The
recommended methodology does not require
any calculations for setting the floodway limits.
[FEMA, with guidance and assistance from
TMAC and Mapping partners]
Experience with an artificially defined standard for
designating a floodway has shown that unless the
entire flow conveyance path is designated as floodway,
negative impacts in terms of increased flood elevations
resulted due to “permitted fill” in fringe areas. The
time has come to accept the primary floodway corridor
nature uses to convey flows also as the “regulatory”
floodway.
9. Require that for regulatory purposes the To ensure that development and encroachment within
mapped floodway for an area with an the prism (foot print) of a levee does not occur, the
accredited levee include the entire foot print of regulatory floodway should extend to landward toe of
ASFPM NFPPR rec and rationale
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the levee through its landward toe and that the the levee. Too often, houses and other building or
regulations should prohibit all development development are allowed on the levee, leading to levee
within the prism of the levee. [FEMA]
failure or overtopping.
10. Establish national program performance
standards for all flood hazard-related data
layers so that data created by state, local, and
other mapping partners can be readily utilized
by FEMA. Performance standards/protocols
can be based on existing state or federal
entities that are already creating some of these
products. [FEMA]
Not all flood hazard-related data layers currently have a
national program performance standard. Such national
standards are needed for program consistency and so
that data developed by various parties can be readily
utilized and relied upon by FEMA.
11. Include various flood hazard-related data
layers, where applicable and when data is
available, on FIRM and work with TMAC and
States/communities to establish new SFHA
zones (such as an “AL” zone for areas protected
by levees or “AD” zone for areas protected by
dams, etc) and locally required regulations (as a
condition to participate in NFIP) to go with it to
discourage economic growth and increased
exposure in flood risk areas. Flood insurance
premiums for such zones should be based on
actual risk (i.e., in addition to expected damage
potential, qualified activities undertaken to buy
down the risk, such as levees, dams, etc.,
should be recognized). [FEMA, mapping
partners]
Due to the significance of their impact at a local level,
some municipalities would like to show various
applicable flood hazard-related data layers on their
FIRM and regulations specific to each. FEMA should
encourage this attitude and allow addition of these
layers to the FIRM, when they are available. FEMA
should also establish new SFHA zones for these floodrelated hazard layers so that flood insurance rates and
premiums can be accurately determined and be
commensurate with the risk.
12. Establish national performance standards for
the development of data layers capturing
expected future-condition flood hazards (as a
result of climate change, projected see level
rise, likely flow increases due to
uncompensated changes in watershed land
use, expected permitted development activities
such as cumulative filling of floodway fringe
areas, and other factors affecting flood–related
risks in the future) and allow inclusion of such
data layers on FIRM when data is available and
requested for inclusion on FIRM by a state or
local mapping partner. [FEMA, TMAC, mapping
partners]
To be sustainable communities need to have access to
reasonably expected future condition flood hazards
data layers. Coming up with national standards for
production of such data layers will be important for
consistency and for strategic planning at a national
level. Also allowing and encouraging the incorporation
of such data layers for the community’s FIRM would
make it easier for those communities, which have such
data available and are willing to regulate at a higher
standard level, to implement such good practices.
13. Review, streamline, and strengthen current
LOMR Delegation guidelines and qualifications
and expand the LOMR Delegation Program to
allow delegation to additional states and state
The current delegation process is quite labor intensive
with MIP entries, tracking, and letter generation.
Streamlining the process would make it attractive to
many more qualified partners to take on this task.
ASFPM NFPPR rec and rationale
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designated local authorities who are willing and Strengthening current LOMR delegation guidelines
qualified to undertake this aspect of program. would help both FEMA and CTPs evaluate their
readiness to share the workload in such a way that it
[FEMA, with mapping partners]
results in a more sustainable system with a better
quality product at a lower price.
14. Delete the rounded, whole-foot elevations While it is understood that the BFE lines are included to
from the BFE lines (“squiggly lines”) on the show water flow and assist the user and may be
beneficial, there is no need to include the whole-foot
FIRM. [FEMA]
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 map
user in an already complicated process to obtain a BFE
at a property or structure for insurance and regulatory
purposes.
COASTAL MAPPING
15. Require Incorporating LiMWAs on all coastal
flood maps, with no-opt-out allowance for
communities (and adopt V zone design
standards for construction of new buildings in
these areas.) [FEMA, mapping partners] OR
Incorporation of LIMWA’s on all coastal flood maps will
alert the regulating agencies of another unique flood
hazard zone that would require an appropriate specific
set of standards; V zones.
16. Develop a unique coastal A Zone definition for The nature of coastal A zones is very different from A
placing on the maps and provide that definition zones in riverine areas. However, currently a separate
in the CFR. [FEMA]
definition for each of these zones does not exist.
NEW MAPPING APPROACHES
17. (a)Delegate authority and funding for mapping
of all flood hazards on NFIP flood maps to
qualified state and state designated local
authorities. Program should allow the mapping
priorities to be developed by the authorized
state and local partners, with input provided by
FEMA. Incentives should be developed to
promote state and state designated local
authorities to provide supplemental funding to
enhance “their” flood hazard mapping.. [FEMA]
(b) Review and strengthen current CTP
guidelines and qualifications so that those state
or local partners selected for delegation would
meet or exceed the FEMA‘s minimum
expectations. [FEMA]
ASFPM NFPPR rec and rationale
Delegation and stewardship of mapping flood hazards
at the state level (and sometimes even at a local level)
is essential to this nation’s road to sustainability. We
should start this process through baby steps of
delegation to willing states and state-designated local
authorities who are qualified and have track record for
such stewardship.
FEMA’s regulations are explicit in requiring the
participation of the States in administration of the NFIP.
44 CFR Part 60.25 Designation, duties, and
Responsibilities of State Coordinating Agencies contains
a list of duties and responsibilities, including: (b)(6)
assist in the delineation of riverine and coastal floodprone areas … and (c) Other duties and responsibilities,
which may be deemed appropriate by the State … may
be carried out with prior notification of the
Administrator. Strengthening current CTP guidelines
would help both FEMA and CTPs evaluate their
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readiness to share the workload in such a way that it
results in a more sustainable system with a better
quality product at a lower price.
18. Require delegated states to develop and
maintain an archival system for all flood map
models for data stewardship and storage in
addition to the Map Service Center. Encourage
and provide funding incentives to all states to
archive flood map data in digital, electronically
transmittable form. [FEMA]
When states are entrusted with production and
maintenance of flood mapping products, they should
be required to maintain an independent archival
system so that all the mapping needs of a state can
eventually be fulfilled under the stewardship of that
state. The engineering models have significant value
and therefore warrant redundant archives.
19. Explore potential changes to current FEMA
practice with regards to funding, production,
storage, management, and stewardship of
various data layers used to produce FIRM or
non-regulatory products. These changes could
include FEMA concentrating its focus
exclusively on the development, maintenance,
and update of flood hazard-related data layers
and rely on/link to other needed non-flood
hazard related data layers that currently are (or
can potentially be) under stewardship,
managed, and maintained by other federal or
state agencies through either independent or
FEMA-supported funding, to produce FEMA
FIRM or non-regulatory products. Under such
proposed scenario, each agency will only be
responsible for the accuracy of the layers under
their stewardship. Each data layer should have
the proper supporting metadata, domain
tables, and other necessary certification and
licensing information consistent with FEMA’s
minimum requirements.
Also under this
proposed scenario, FEMA should maintain
meaningful links to those non-FEMA
maintained data sets, utilizing the most
appropriate data sharing protocols, and ensure
that data sets are available at least until any
reference to them would only be for historical
purposes rather than legal or insurance
purposes. [FEMA, with guidance from TMAC,
mapping partners]
Currently, the responsibility for funding, production,
storage, management, and stewardship of various data
layers used to produce FIRM or non-regulatory
products all rest with FEMA. This puts an enormous
burden on one agency and in many cases leads to
duplication of efforts by other federal and state
agencies that have primary jurisdiction and expertise
over some of these data layers. This also distracts
FEMA’s efforts from ensuring that an accurate flood
hazard layer is produced and maintained for all the
nation’s flooding sources. Agencies should focus their
efforts on producing and maintaining data layers
(rather than “maps”) for those products under their
traditional stewardship (such as stewardship of USGS
with regards to topographic data layers, Stewardship of
FEMA with regards to flood hazard-related data layers,
etc).
Flood hazard-related data layers include, but are not
limited to:
i. a fully digital national flood hazard data layer
(Primary focus for NFIP);
ii. coastal
erosion
and
riverine
fluvial
erosion/channel migration zones;
iii. areas protected by dams, levees, diversions,
reservoirs, and other structural projects
(delineated simply by assuming the structural
measure has failed);
iv. areas with repeat flood damage claims and
adjacent areas with repeat flooding histories;
and
Other special flood hazard-related layers (such
as subsidence zones, etc)
20. As a long-term vision and a logical follow up to Many state and local land use planning and regulating
ASFPM NFPPR rec and rationale
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the proposed changes discussed above with
regards to funding, production, storage,
management, and stewardship of various data
layers used to produce FIRM or other nonregulatory products, the NFIP should consider
transitioning its “map” production system to a
fully digital decentralized system.
As
experience is gained focusing on management
and maintenance of “flood hazard-related data
layers” versus “flood maps” as its primary
responsibility with respect to mapping
products, FEMA, with guidance and assistance
from TMAC and mapping partners should move
towards a map processing system where the
primary “mapping” product from the agency
will be the flood hazard-related data layers. In
such a system, a “map” is prepared through
overlaying of appropriate mapping layers
applicable to a state or a local community.
Printing on demand, and distributing such
mapping products can be delegated to qualified
mapping partners based on guidelines
developed by FEMA. [FEMA, with guidance
from TMAC, and mapping partners]
agencies are already capable and/or will soon be
capable of producing their own “maps” through
overlaying the hazard layers important to them on local
road maps or best aerial maps with the community
boundaries they maintain. This will bring about
sustainability of the mapping program and buy in at the
state and local level. While this will not be
implemented over night, it should serve as a long-term
vision for future of “flood map” production in this
nation.
21. Consider placing an expiration date on all Flood
Insurance Studies and Flood Insurance Rate
Maps (and make the non-expiration status of
FIRMs in a community as a condition for the
community’s eligibility for NFIP participation).
An evaluation of the accuracy and applicability
of the FIRM data will need to be conducted
prior to expiration and the data either revalidated or revised prior to assigning a new
expiration date. This recommendation has to
be dovetailed with planned map update
funding cycles so that the community is not
penalized as a result of FEMA’s funding
priorities. [FEMA, TMAC, mapping partners]
The FIRMS are based on existing conditions. Therefore
some assessment should be made as to how long the
FIRM is reasonably accurate for (likely max of 5-15
years). The duration of valid and accurate data will
likely differ based on uniqueness of hazards in each
area and outside influences (such as watershed
development, change in rainfall characteristics,
presence of active subsidence, etc.)
ASFPM NFPPR rec and rationale
Page 6 of 6 Mapping-Section A
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