Ariz. CRS Users Group Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 28 -- Tim Murphy of the Arizona CRS Users Group has issued a public comment on the Federal Emergency Management Agency notice entitled "Request for Information: National Flood Insurance Program's Community Rating System". The comment was written on Sept. 23, 2021, and posted on Sept. 27, 2021:

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The Arizona CRS Users Group is pleased to offer the following comments on the National Flood Insurance Program's (NFIP) Community Rating System (CRS). Currently 27 of Arizona's communities participate in CRS, and many of them have since the program was first implemented. These communities represent 81% of the NFIP policies in Arizona.

1) Although most of the Communities represented by the members of the User Group have been involved with CRS since its early implementation, many members expressed concerns that joining CRS is hard and that staying in the program is also hard. This is a concern because with the changes coming because of Risk Rating 2.0 there could an increased focus on a community's CRS Class, and there could be pressure for communities to improve their class. We also believe that more Arizona communities will be interested in joining CRS if they see it as being beneficial as Risk Rating 2.0 is being implemented.

2) If Risk Rating 2.0 significantly increases flood insurance premiums, this could cause communities to engage in actions just to increase their points and chase premium discounts.

3) Several members expressed concerns about the documentation requirements and that they are becoming more cumbersome and burdensome. They feel that they are creating documents to just document their activities. In 2014 the Arizona CRS User's Group conducted a survey of its members to get an understanding of the amount of effort required by communities for Cycle Visits and Annual Recertifications. The results were shared with members of the CRS Task Force, and can be reshared with the current Task Force. The Arizona CRS User's Group is willing to conduct an updated survey amongst its members and share those results with the Task Force. We also recommend the CRS Program conduct a similar survey with CRS communities in order to get an understanding of the efforts required by communities to document their activities for Cycle Visits and Annual Recertifications. Besides obtaining information on the hours expended by the community, the updated survey should also include questions about the use of consultants.

4) Many members felt that the program is becoming too technical and too expensive. As an example, some communities are needing to use consultants to help them with their CRS programs. These consultants are being used to help prepare the documentation and exhibits needed for Cycle Visits and even Annual Recertifications. Consultants are even being used to help develop and administer certain activities. The reason for this is the growing complexity of the program and the likelihood that most community CRS Coordinators are only involved in one or two Cycle Visits. They usually leave the community or their duties are changed. The use of consultants is increasing the costs for a community's participation in CRS. Unfortunately, many communities are unable to afford consultants, so they are unable to improve their classification, or they think they can't even get into the program. This has the unintended consequence of leaving economically disadvantaged communities behind.

5) One way to increase the number of communities participating in CRS is for FEMA to provide funding to build capacity for regional CRS coordination amongst communities. In Arizona many counties have strong Flood Control Districts that could lead these regional efforts. Funding from FEMA could be used to start these efforts. We feel that the current ISO staff is too busy to devote enough time to effectively help communities join the program or work with communities to improve their classification. Additional staffing is needed at the regional, state, or even within ISO that can focus on helping communities.

6) Another general concern is that changes to the CRS Coordinators Manual creates hurdles for communities. Just as a community begins to feel that is becoming familiar with the requirements of the manual, CRS goes and changes the manual. This requires the community to spend time learning the new manual, and revising its activities to conform to the new manual. We have even heard that some communities have been given a very short notice that their cycle visit will conducted using a newer version of the Manual. This caused the community to lose points because all of their efforts for the last several years were based upon the previous manual. Communities need a year or more notice when they will be scored using a different manual.

7) Many of our communities feel like they are having to force a square peg into a round hole. They are having to revise their programs to better align with CRS' requirements they don't feel like changing their process was an improvement. Or that following CRS' process improved the effectiveness or usefulness of the final product. Too often the changes were made just so that the community could obtain some points, or maybe some additional points.

8) We have concerns about CRS continuing to have an emphasis on Elevation Certificates. With the introduction of Risk Rating 2.0 there seems to be less of a need for using ECs to determine flood insurance premiums. We understand that CRS originally placed importance on ECs because of their use in determining flood insurance premiums. That no longer seems to be the case, and we believe significant changes can be made to Activity 310.

9) We feel the approach to scoring the Activities in the 600 Series needs a major revision. Many community floodplain managers and emergency managers have processes that work for their communities. Unfortunately, these don't match exactly with CRS' requirements, and the current scoring practice gives them zero points. This approach completely ignores the good work communities are doing. This approach punishes communities instead of rewarding them. This approach has hurt several communities in Arizona. Communities should be able to receive some credit when their actions meet the criteria for even 1 or 2 elements.

10) Local communities shouldn't be penalized in the 600 series when federal or state agencies are unable or unwilling to share information. The local community can't be responsible for the actions of these higher levels of governments. Local communities have to trust that these other agencies are undertaking the actions necessary to protect and warn downstream communities. Also, local communities usually don't have the authority to enforce other communities outside their jurisdiction to share information.

11) We have concerns about the various planning efforts in CRS. Local communities are already required to develop various plans, and CRS requires them to develop even more plans. If the community doesn't do these additional plans, they usually receive a low score from CRS because they didn't follow all of CRS' steps. For any of these plans the requirement to update them every 5 years is often too short of a time period. There usually aren't substantial changes in a watershed or the floodplain to warrant the frequent updates.

12) We would like to see changes made to Activity 410 Floodplain Mapping. We feel the focus should be keeping the FIRMs up to date, and the scoring should reflect this. The requirement that for existing delineated areas that the BFE needs to be increased or the limits changed horizontally should be dropped. Communities should be rewarded in CRS for doing floodplain delineation studies that keep the FIRMs up to date. Also, credit should be given for actions that enable Risk Rating 2.0 to determine more credible premium calculations. Many communities are now doing studies with 2-dimensional models that provide more detailed information. CRS should find a way to reward communities for doing these more detailed studies.

13) We like to see more flexibility for outreach activities, especially regarding the development of a PPI.

The current requirements make it difficult for communities to work together on developing regional outreach programs. Once again CRS seems to penalize communities for not following the CRS formula.

The requirements for developing the program need to be less rigid, and instead the focus should be on what is being done for the community or communities.

14) Consider developing an impact adjustment multiplier based upon a community's economic status. This could be an incentive that enables disadvantage communities to participate in CRS.

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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0021-0001

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