Cabarrus Deputy County Attorney Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 18 -- Cabarrus County Deputy County Attorney David Goldberg, North Carolina, 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 posted on Sept. 17, 2021:

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I request a 30-day extension of the deadline for comments. This should provide sufficient time for FEMA to provide responsive documents to two of our Freedom of Information Act requests. I believe these documents will provide critical information on how FEMA currently manages the CRS program through a personal services contract with Insurance Services Office (ISO), Inc. operated outside of the Federal Acquisition Regulations and standard appropriations requirements.

I believe the documents will also provide further context on FEMA's recent decision to protect ISO from the competitive bidding procurement processes because "No other vendor is capable of providing the required services of this national program that has only been administered by ISO."

FEMA Community Rating System (CRS) Program - NOTICE OF INTENT TO AWARD A SOLE SOURCE (Jun 29, 2021), https://bit.ly/3ziPrNc. Essentially, FEMA's rationale to not consider alternative providers is because it has never considered other providers previously.

Our comment focuses on how decisions like this impact local governments' experience with the CRS Program and how operating the program with greater transparency and compliance with federal laws and procedures will improve participation and reduce national flood risk. The additional 30 days will help ensure that FEMA receives the maximum benefit from our comment.

Additionally, FEMA has received over 70 public comments, with more coming in daily. Given this high level of public interest, extending the deadline would likely provide others with enhanced opportunities to submit a comment, as well as respond to previously submitted comments.

Thank you for your consideration.

David Goldberg

Deputy County Attorney

Cabarrus County, North Carolina

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

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