National Flood Policy—ASFPM 2015 Recommendations
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
(Referring to section Q in general) Can these
recommendations be integrated into the other
sections?
Q.2. Amend Disaster Relief Act to apportion costs,
responsibilities, and roles among federal, state,
local governments, and the public commensurate
with risk (for example, a sliding cost share could be
used as an incentive)
Define “sliding cost share 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
This is qualitative and would be impossible and
highly political to administer. Who decides what
the share % is for each community for each
activity.
Clarify
Recommendation to delete completely: There is a
sliding scale for communities for PA using the
poverty index. Reduced cost share can be
requested as MS and LA did for Katrina. This is not
needed.
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 Assistance 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
Combine with Q.4
==Change to say that ALL Federal disaster
assistance is contingent……..
HMA eligibility is contingent on NFIP participation.
PA is not
UNCLEAR. WHICH STANDARDS?
Keep in mind, the feds would have to do this
determination, and right now there is no “national
standard” for infrastructure. May not even be legal
unless interstate commerce is involved. Delete for
now, it’s an emerging area.
Q.7. Amend existing law so that communities
would be allowed to bank mitigation expenditures
as non-federal share of next disaster
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National Flood Policy—ASFPM 2015 Recommendations
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 (disincentives to wise use of
floodprone lands) and tie all such taxpayer support
to producer conservation compliance.
This could further encourage conversion of
agricultural lands to developed land if the farmers
lose these programs. Better crops than houses in
these areas.
Alternatively, explore the impacts of decoupling
flood losses from the Multiple Peril Crop
insurances to develop appropriate and sustainable
land uses within floodplain lands and to minimize
the chance that farmed floodplain land is not
converted to residential/commercial development.
Will we see a massive sale of crop lands – making
them prime for development?
Farm community relies heavily on crop insurance
as a risk management tool so that when a disaster
comes, the political support is not there provide
disaster aid. Reducing the subsidy will not support
this concept.
Also phrased “Use incentives to encourage
alternative, sustainable crops in floodprone areas”
Revise to be clear about the relevance to flood
risks
USDA – esp. NRCS and FSA have lots of programs
that do this. EPA and states do as well. Delete.
Q.12. Deny subsidized crop insurance and disaster
payments to agricultural producers with repetitive
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
This would create an incredible outcry in the
agricultural and business community. Not advised.
Reword as incentive ==Either drop this alternative
crop concept or define what it is? Then evaluate
whether those alternative crops are really
sustainable
This exists, its NEMA’s Emergency Management
Assistance Compact (EMAC.). Well proven and not
necessary to create another system.
Q.14. Delegate (with monitoring) to qualified
states the administration of flood mapping, HMGP,
FMA, CAP, and environmental reviews for
mitigation projects
This is the CTP. Others addressed in H. Mitigation.
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.)
If this is an expansion of CTP, leave, otherwise
delete.
NFPPR Combined comm rec and comments
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National Flood Policy—ASFPM 2015 Recommendations
Q.16. Make CAP funding contingent upon the
state’s provision of one fully funded professional
full-time position—a CFM in floodplain
management
Some states may not have issues funding NFIP
support staff but need CAP funds for other
activities. Not our place to get in-between FEMA
and states on CAP.
Q. 17. Encourage market-driven private-sector
incentives for mitigation
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
This would be very difficult as FEMA reservists
cannot predict future land uses and the local
political will. They follow the local floodplain
management ordinance, that’s about the best we
can expect.
Q.20. Prohibit the use of federal funds to build
any infrastructure to serve currently undeveloped
SFHA. Combine 19-20
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.
NFPPR Combined comm rec and comments
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draft 10 9-14