Association of State Wetland Managers Issues Public Comment on FEMA Notice

WASHINGTON, July 27 -- Marla J. Stelk, executive director of the Association of State Wetland Managers, Windham, Maine, has issued a public comment on the Federal Emergency Management Agency's notice entitled "Technical Mapping Advisory Council; Meeting". The comment was written on July 21, 2020, and posted on July 24, 2020:

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The Association of State Wetland Managers (ASWM) submits the following comments to the Technical Mapping Advisory Council (TMAC) regarding the proposed vision statement for the Federal Emergency Management Agency's (FEMA) mapping program per Federal Register Docket ID FEMA-2014-0022.

ASWM is a nonprofit professional organization that supports the use of sound science, law, and policy in development and implementation of state and tribal wetland programs. Since 1983, our organization and our member states and tribes have had long-standing positive and effective working relationships with federal agencies in the implementation of both regulatory and non-regulatory programs designed to protect our nation's aquatic resources.

ASWM is a founding member of the Natural Floodplain Functions Alliance (NFFA), an affiliation of nonprofit and private organizations, government agencies and individuals dedicated to the protection and preservation of the natural functions of floodplains, including coastal areas. ASWM is also a founding member of the Wetlands Mapping Consortium (WMC), an interdisciplinary group of wetland scientists and managers interested in mapping and monitoring wetlands with remotely sensed images and/or using the resultant products to best manage wetland resources.

Given ASWM's focus on natural aquatic ecosystems, including wetlands, streams, coasts, and the floodplains that contain them, the comments below are focused solely on that aspect of FEMA's mapping program.

FEMA's Fact Sheet titled "The Community Rating System works to Protect Natural Floodplains" states that the Community Rating System (CRS) of the National Flood Insurance Program (NFIP) "rewards a community-centered approach to reducing flood hazards that also protects the natural and beneficial functions of a community's flood-prone lands." Further, the fact sheet states:

"The CRS promotes comprehensive floodplain management planning, analysis and evaluation related to the protection of the natural functions of floodplains and habitat protection. Credit is available for community-adopted management plans that protect and enhance one or more of the natural functions and native species of the local floodplain. The CRS encourages analysis of the potential impacts of growth and development on the local environment, followed by implementation of specific projects for protecting and restoring habitat and other natural functions."

The CRS program issues credits to communities that produce maps of the natural functions and resources of their flood-prone areas. Unfortunately, many communities are ill-equipped to produce maps of floodplain and wetland functions, generally due to a lack of expertise, a lack of understanding regarding the importance of floodplain functions, and/or a lack of funding. With the significant increases in flooding events, both natural disasters and "nuisance" flooding, communities find themselves embracing the old "tried and true" structural methods for flood control such as sea walls and groins, as they are well understood strategies, supported by existing federal programs and regulations.

Floodplains exist within a greater watershed context and the functions that they provide vary depending on the condition of the floodplain and other land uses within the watershed. As such, floodplain maps that provide data on floodplain functions and condition need to be created on a watershed scale. However, FEMA's Risk Mapping, Assessment and Planning (MAP) program generally only includes data on elevation, hydrology, infrastructure, hydraulics and land use for the purpose of informing NFIP rates, not data on natural system functions which can reduce flooding, improve water quality, or consider significant habitat which might be critical for endangered or threatened species.

Currently there are efforts among several other federal agencies, to create maps and data on wetland and floodplain functions, such as the U.S. Forest Service's National Riparian Inventory Base Map (which recognizes the dynamic and transitional nature of riparian areas by accounting for hydrologic, geomorphic and vegetation data as inputs) and the hydrogeomorphic approach (HGM) used by the U.S. Army Corps of Engineers for compensatory mitigation projects to ensure that any impacted wetland or stream functions are replaced by the mitigation project. Additionally, the U.S. Fish and Wildlife Service's National Wetlands Inventory (NWI), which now incorporates hydrography data, included past efforts to evaluate natural wetland function on the landscape.

FEMA's floodplain management efforts would be dramatically improved if they were informed by geospatial data that illustrates floodplain functions (including wetlands, coastlines, streams and rivers) as dynamic, hydrologically connected components of a larger watershed to support more strategic local land use decisions (e.g., restoration and/or open space conservation priorities), reducing flood risk while increasing co-benefits such as recreation, clean drinking water, habitat for threatened and endangered species, and avoided damage costs.

ASWM appreciates the opportunity to provide comment to TMAC on priorities for FEMA's mapping program and vision. While these comments have been prepared by ASWM with input from the ASWM Board of Directors, they do not necessarily represent the individual views of all states and tribes; we therefore encourage your full consideration of the comments of individual states and tribes and other state associations. Please do not hesitate to contact me should you wish to discuss these comments.

Sincerely,

Marla J. Stelk

Executive Director

Association of State Wetland Managers

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The notice can be viewed at: https://beta.regulations.gov/document/FEMA-2014-0022-0044

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