National Flood Policy—ASFPM 2015 Recommendations
C. Stormwater & Watershed Management 11-20-14
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; 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]
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 reduction of minimizing the increase in future
flood hazards.
This may require modification of current
watershed planning guidelines from EPA to include
flood hazards.
(c) Consider both flood risk reduction and water
quality benefits in all FEMA HMGP and
Environmental Protection Agency Section 319 and
Smart Growth and Resilience demonstration
projects [FEMA; EPA]
C. 2. EPA and States 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. [States]
C.3. Wetlands 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]
NFPPR rec and rationale
Without the control of increased runoff (peak and
volume) of runoff from new development, the cost
of development is transferred from the developer
to those with property downstream. Several
states mandate matching the peak flow for one or
more design events for the pre-development
condition and post-development. It is much
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
for the benefit of the downstream. This will also
outline the potential liability for changes that
might damage downstream investments or assets,
as would C4.
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National Flood Policy—ASFPM 2015 Recommendations
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, or greater,
, to prevent the erosion of stream channels,
pollution, and damage to adjoining structures
during these events which creates more pollution.
C.4.(b) EPA and FEMA should collaborate to
address the disconnect between water quality and
quantity focus that results in only addressing one,
but which may exacerbate the other.
[EPA; FEMA]
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 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.
This is needed to ensure that their programs
complement each other as much as possible.
The rec and discussion in (a) needs review
C.5 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
somehow to appropriate agriculture practices.
[EPA]
NFIP support of effective Stormwater programs
C.6. As a prerequisite for Class 4, CRS communities
must require all new development and
redevelopment to use LID techniques to the
maximum extent possible for each site to mitigate
their impact. [FEMA]
C.7. 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]
Moved to K 8 by LL-- IS this OK?
Small feeder streams are critical to downstream
water quality and natural ecosystem functions
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 use the techniques that are
appropriate for their community. This relates to
floods by reducing increased flows at all levels 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
Carlton rec delete this one
Writing team should discuss the entire row below
Dave, we do comment on and look at Waters of
the US permits under 404 and 406 of CWA.
Should we say something about that? Or other
water quality issues? LL I don’t know enough
about the specifics of 404 or 406 except to know
NFPPR rec and rationale
Shouldn’t we have more to comment on Water
Quality than just stormwater management? Other
stressors on water quality includes:
•Development encroachment and loss of habitat ,
•Invasive species
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National Flood Policy—ASFPM 2015 Recommendations
permits are sometimes needed. (404 Mentioned
in K and that might be a better place.)
We could comment specifically on everything if we
wanted to as I imagine we generally support anything
that increases water quality. Buffers as well as the MS4
permit address all these issues if done well. The
purpose of the MS4 permit is to address many of these
issues and each state does to a varying degree. We
should support activities to reduce erosion and
pollution (MS4). Maybe include a recommendation on
reducing the maximum land area not requiring a permit
from one acre to one-half acre and to address the
impacts of agriculture. Carlton
NFPPR rec and rationale
•Water chemistry alterations/ increasing acidity
•Thermal stress
•Flow alteration (not just stormwater alterations,
but also from ditching or alterations of wetlands,
withdrawals for drinking water or snowmaking,
•Land erosion
•Nutrient loading
•Pathogens and toxins
--CWA permits, WOUS
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