Association of State Floodplain Managers Issues Public Comment on FEMA Proposed Rule

WASHINGTON, April 7 -- Meg Galloway of the Association of State Floodplain Managers, Madison, Wisconsin, has issued a public comment on the Federal Emergency Management Agency's proposed rule entitled "Revisions to Publication Requirements for Community Eligibility Status Information Under the National Flood Insurance Program". The comment was posted on April 6, 2020:

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ASFPM supports the two proposed changes to the Code of Federal Regulations regarding publication requirements for the National Flood Insurance Program (NFIP). The first proposal changes the requirement that community loss of eligibility notices must be published in the Federal Register. The second proposal is to revise and remove the regulation requirement that FEMA maintain a list of communities eligible for flood insurance in the Code of Federal Regulations.

In the past, communities have been listed in the Federal Register as being eligible for NFIP suspension when they are within one month of the deadline for adopting a new Flood Insurance Rate Map. This occurs due to the lead time needed to publish in the Federal Register.

In most cases, communities are working in good faith to adopt the new maps. Being shown as "eligible for suspension" creates anxiety at best and at worst, results in some people erroneously losing flood insurance eligibility. The Federal register is also not an easily usable information source for the average citizens to access as a reference for the status of community NFIP status.

While the Federal Register may not be the best location for such information, it is essential that FEMA support a robust and easily accessible online viewing platform for the NFIP status of all communities and the ability for everyone to access which communities are eligible to join the NFIP.

It is also critical that the new process assures that State NFIP Offices and local communities be promptly notified when a community faces possible suspension or probation. Timely notification can allow the State NFIP Coordinator time work with the at risk community to avoid the pending action.

The proposal to use the Community Status Book for the potential loss of eligibility information makes sense. Another platform will need to be developed for the listing of communities eligible to participate in the NFIP. Whatever form that takes should be tied back to the community status book so that an unsuccessful search for a community in the Community Status Book would refer the user to the list of eligible communities.

It will be important for FEMA to do outreach on these revised processes. FEMA should work, in coordination with their state and local partners, to message the changes and improve awareness of the Community Status Book as an important NFIP resource.

The changes should also be reflected in their printed and online educational and outreach materials. It will also be important to remember that not everyone is comfortable finding information in an online platform and accommodations will need to be made for those that cannot access information online.

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The proposed rule can be viewed at: https://www.regulations.gov/document?D=FEMA-2019-0016-0001

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