Cupertino Public Works Department Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 23 -- Chad Mosley, assistant director of the Cupertino Public Works Department, California, 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 and posted on Sept. 22, 2021:

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The purpose of this document is to summarize public comments made by the City of Cupertino requested by FEMA on recommended improvements to the current CRS Program. These public comments were formally submitted via the Federal eRulemaking Portal (www.regulations.gov) on September 22, 2021.

CRS Program Recommendations:

* FEMA should consider setting a lower criterion for earning credits in the CRS program for smaller communities. Currently, CRS operates as a "one size fits all" program where the same criterion applies to all participating communities regardless of geographic location, population within and acreage of Special Flood Hazard Areas (SFHA). The City of Cupertino understands the importance of floodplain management/protection and the valued flood insurance cost savings the City's voluntary participation provides to its community members. However, as a smaller community, Cupertino staff size and capabilities are limited and already taxed with workloads to comply with the current CRS program. If criteria become more stringent, the City is concerned staff may not be able to meet the program's demands, the costs to operate the program would not outweigh the benefits, and may consider withdrawing from the program.

* FEMA should reconsider the penalty structure for elevation certificates reviewed under Activity 310 for smaller communities. When an elevation certificate is required, it is completed by the required party and reviewed by City staff. A community should not be fully penalized for data that is formatted differently or which is adequate to address the community needs, such as penalties for not providing the full community panel number when only the last 5 digits are sufficient to locate the proper map within a city (e.g. 06085C0209H versus 0209H).

* FEMA should consider better consistency when an ISO reviewer is assigned to a community due for their cycle visit. In the middle of Cupertino's 5-year cycle visit last year, the current ISO reviewer took an unexpected leave of absence and was replaced with an ISO reviewer who was not familiar with Santa Clara County or the important lead role Valley Water plays to the CRS-participating communities within the County. As a result, Cupertino staff had to provide additional documentation that required quite a bit of coordination between the City and Valley Water in order to justify credits the City should receive under Activity 540. These were credits the City had received in previous years. Ultimately, the City received 0 credits under Activity 540, compared to 255 credits received in the previous cycle visit.

Sincerely,

Chad Mosley

Assistant Director of Public Works,

City Engineer & Floodplain Manager

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

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