National Flood Policy—ASFPM 2015 Recommendations
O. Disaster Management & Assistance
O.1. Ensure that interagency mutual aid efforts
are structured to easily allow local floodplain
management and flood hazard mitigation needs
to be addressed
a) Explicitly allow substantial damage
determinations to be eligible for
reimbursement under PA which would
make EMAC a more viable approach
b) Encourage all states to have laws that
allow in-state mutual aid which addresses
liability and credentialing of volunteers
c) Establish mutual aid programs for
floodplain managers within all ASFPM
chapters.
Interagency mutual aid programs can be very
helpful to help address floodplain management
issues post-disaster. However EMAC – which
allows interstate mutual aid doesn’t work well
primarily because FEMA has a policy that
specifically disallows substantial damage
determinations to be reimbursed under PA. In
states where the ASFPM chapter has facilitate instate mutual aid, substantial damage
determinations have been done better and faster
(Oklahoma, Ohio, Georgia, etc.)
O.2. Restore FEMA to independent agency status
to allow for greater flexibility in achieving their
mission objectives.
FEMA continues to have issues related to being
part of DHS – from the DHS “tax” to needing to
conform with broader DHS fiscal, accounting, and
other programs, in the post-disaster
environment, this complicates and delays
programs like HMGP and doesn’t allow FEMA to
be as nimble. Should this recommendation be
under Federal Leadership section versus postdisaster? It doesn’t seem to fit very well here.
The national level frameworks that exist today
are collectively called the National Planning
Frameworks.
O.3. Ensure that flood loss reduction concerns
are addressed throughout the national planning
frameworks including the National Response
Framework, National Recovery Framework and
National Mitigation Framework
O.4. Make the availability of and amount (slidingcost-share)of disaster assistance contingent upon
taking local/state mitigation action
a) However, NO federal disaster assistance
program or mitigation program should be
100% federal. There must be at least a
minimal amount of non-federal costshare to ensure state/local commitment
This recommendation aims at incentivizing
community action to mitigate and make
themselves more resilient.
O.5. Make all federal agency disaster assistance
contingent upon the community and state having
an effective updated hazard mitigation plan and
community participation in any available predisaster mitigation program for which hazards
pose a significant threat in the plan
Flood losses continue to increase. Disaster
assistance has been identified by many policy
experts as a primary driver to not changing
behavior of communities and individuals to be
more resilient. Communities should participate
in all voluntary programs that help reduce the
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a) For significantly flood prone
communities, assistance should be
contingent on NFIP and CRS
participation, compliance, and
maintenance of insurance for all
structures in the SFHA
b) For small and under-resourced
communities and tribes, ensure
availability of technical assistance to
initially help them with participation in
the mitigation program(s)
O. 6. Improve the capacity of the JFO to deliver
mitigation programs timely and effectively
a) Improve the efficiency and delivery of
HMTAP by allowing FCOs to approve
requests consistent with the state’s
mitigation strategy versus FEMA Regions
or FEMA HQ.
b) Require FCOs to be trained in mitigation
programs and include mitigation program
delivery goals as part of their personnel
evaluations
c) Ensure that JFO operational goals equally
value the effective delivery of hazard
mitigation programs as the delivery of
disaster recovery programs
d) Study and develop consistent national
minimum recommendations for
mitigation program staffing at JFOs
e) Establish a goal and plan/process for
supplementing state capacity for the
expedited acquisition of flood prone
buildings within six months of the flood
event if a state includes acquisitions as
part of its mitigation strategy.
f) Require that for every PA Project
Worksheet that at least one mitigation
measure is identified, regardless if it is
eligible for PA funding, and require that
such data be shared with the property
owner and community.
O.7. Ensure that actions undertaken pursuant to
emergency action plans do not cause adverse
flood impacts on other properties in the
community or other communities, or on natural
floodplain function and storage.
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risk of a particular hazard they are vulnerable to
before federal disaster aid is provided.
JFO operations are inconsistent and generally
provide poorly timed and/or inadequate
mitigation resources. The operational goals of
JFOs and FCOs is usually to close the facility as
fast as possible and do so with as little cost as
possible. There are several improvements that
can be made to make mitigation program
delivery successful.
The first step to make 406 mitigation successful is
to write up mitigation measures as part of the
project worksheet process. That also means that
knowledgeable mitigation staff must be
embedded into PA-PW teams.
When the levee in Cairo was blown up the
properties that were flooded already had
easements that allowed them to flood. Such
foresight and thinking should go into all
emergency protective measures. Entities
undertaking protective measures will continue to
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O.8. Work with all federal agencies to ensure
post-disaster policies and programs are
consistent in supporting long-term flood loss
reduction, always consider non-structural
alternatives, include national
resilience/sustainability goals and factor in
climate change.
a) Require that all PL 84-99 projects
consider non-structural measures
b) Require all federal investements in
rebuilding/reconstructing critical facilities
be protected to the 500-year flood level
be liable for damages that occur on other
properties due to their actions as the “act of
God” defense is largely not valid as such events
are predictable.
More recently, the White House has established,
as a matter of national policy, several directives
towards resilience and sustainability. This will be
a focus of agencies until at least the end of this
administration if not beyond. Also, there are
program that actually promote s that
O. 9. Develop mechanisms where FEMA can
easily and quickly provide relevant damage
assessment and flood insurance claims data ondemand to state and local floodplain managers to
support substantial damage determinations.
Currently data that is shared comes too late, is
incomplete, or is unavailable. Privacy Act
concerns notwithstanding, basic information
related to damaged buildings should be easily
available to floodplain managers to help support
their required duties in performing substantial
damage determinations.
O.10. Create a comprehensive database,
The lack of a standard framework makes it
standardized estimation techniques and
extremely difficult to accurately identify trends in
framework for compiling total loss estimates from natural disaster losses. Moreover, this inability
individual disasters, including federal
makes it more difficult for the federal
expenditures, economic damages, insurance
government to identify which disaster mitigation
payments, etc.
policies represent the more cost-effective
a) This could be part of the National Climate options.
Data Center (NCDC) storm data collection
effort
The idea of collecting these data and
b) These data should be incorporated into
incorporating them into the DOC economic
the US Dept. of Commerce collection of
statistics is a recommendation made by the
economic statistics
National Academies of Science a decade ago.
Q 11. Establish an independent board similar to
the National Transportation Safety Board, to
collect investigate disasters; collect data; analyze
the damages, causes and economic, social and
environmental impacts; evaluate effectiveness of
government programs and make loss reduction
recommendations. The board’s
recommendations should be made public through
a report for each event.
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This is a recommendation that had been made by
Bill Hooke with the American Meteorological
Society.
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O.12. FEMA, in consultation with other
appropriate federal agencies, develop mitigation
related metrics that are used to measure the
success of a post-event disaster recovery. Require
that mitigation metric be developed by MitFLG
and used as an indicator of a successful disaster
management and recovery.
O.13. Develop an effective and expedient process
that the state and/or FEMA can review states and
communities for compliance with NFIP
requirements and quickly impose sanctions if
necessary.
The national mitigation framework exists as part
of the national planning framework. However,
what seems to be missing are performance
metrics.
In the post-disaster environment, states can
make poor policy choices and establish policies
that conflict with the NFIP. Some communities
choose not to perform substantial damage
determinations. In these situations, FEMA must
be able to act quickly to warn of and impose
sanctions if necessary.
O. 14. Require detailed tracking and enforcement Cross-reference to similar in G insurance
of required flood insurance on Group Flood
Insurance Policies and flood insurance on SBA
Disaster Loans post-Flooding. Flood insurance
should also be required on SBA Disaster Loans
that are in NSFHAs.
O.15. Foster productive recovery partnerships by
providing joint pre-disaster training and exercises
on rebuilding with resilience for Federal staff,
state agencies, and tribal, territorial, and local
leaders in vulnerable areas, including on
resources, requirements, and opportunities.
Exercises should be based on strategies identified
in local hazard mitigation plans or pre-disaster
recovery plans.
O.16. Support/develop/promote apps or other
crowd-sourcing approaches for immediate
disaster notification or for post-disaster recovery
information dissemination.
The emergency management community
effectively uses exercises to build and maintain
capability, yet these rarely if ever extend to
hazard mitigation and other resilient recovery
efforts. By developing training and exercise
focusing on this aspect of recover, community
capabilities can be built and lead to a faster and
more sustainable recovery effort overall.
O.17. Make stream gages more versatile by
applying technologies to help with risk
assessment and flood warning such as flood
inundation mapping, connectivity with land and
web based flood warning/alert systems, and
better integration with HAZUS.
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