Douglas County Issues Public Comment on FEMA Notice
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1) What are the strengths of the current CRS program? What components of the program are currently working well and why?
a. Currently, it is difficult to identify specific points within the CRS that are working well. A benefit of CRS is that it incentivizes governments to engage with the public and disseminate information in places where it previously was not. Prior to being a part of CRS, our community did not have information available in the local public library and we had minimal information on our website.
b. CRS has been a tool our community has used as leverage when interacting with property owners to talk them out of developing in or near the floodplain. Involvement in the CRS has helped our community remediate various building and zoning violations.
2) What are the challenges with the current CRS program that need to be addressed and why? How can the CRS program be modified, expanded, or streamlined to better address or resolve these challenges?
a. The CRS manual, with addendum, is currently in excess of 700 pages. Smaller communities such as ours have difficulty in finding the time to thoroughly review the manual, much less take each chapter and develop material/programs. Our community has reviewed the amount of dollars community members saved and have compared it to the amount of employee hours spent trying to figure out how to implement various pieces of the CRS manual. We concluded that we are expending more in revenue in staff time than our community members are receiving in discounts. While CRS offers additional tools and leverage that we may not have otherwise had, there have been informal discussions about leaving the program.
b. A potential fix to the CRS manual could be:
i. Having a shortened version that discusses the goals and intent, followed by two or three prime examples. The shortened version would be no greater than 100 pages with simplified goals and implementation tasks.
ii. Providing basic templates along with examples would help many communities not have to create everything from scratch. Creating and continuing to log and track all these items is resource and time intensive.
iii. There is not enough one on one training or resource agents in the field assisting communities to help them be successful. As employees turn over, the institutional knowledge is lost and a new employee must pick up the program with a blind eye. This program should be created and centered around a basic enough program that any employee having the will and some basic knowledge could accomplish it.
iv. Having a CFM on staff should be enough to qualify for the program. CRS is so time intensive and exhaustive of staff time and resources with very little understanding from
v. If you go to the
vi. The program is cumbersome for as little benefit as it provides to communities.
3) While the CRS program is technically available to all compliant NFIP communities, is access to the CRS program equitable for all communities? If not, what changes to the CRS program could make it more equitable for all communities? How could the CRS program provide better outreach to disadvantaged communities to encourage participation? How could the CRS program provide better outreach to households in disadvantaged communities to encourage participation in the NFIP?
a. No program that bases everyone on the exact same criteria, ignoring socio-economic status, size, and topography, of a community can consider itself equitable. Many larger communities have the ability to assign one or more people to focus their entire energy on floodplain related duties (to include CRS). In most communities, everyone involved in zoning, planning, and building codes wear multiple hats. This is common for many smaller communities. It would be nice to know the size of all the communities in the CRS program.
b. The entire program is regressive. There is very little help to communities who cannot afford the staff. Communities that continue to flood have higher flood insurance, many do not have zoning and most certainly do not have the staff to enroll in CRS. The people who need the help the most are not getting it because they don't have the ability to fund employees, who need training and certification for such programs.
4) How could the CRS program better promote and/or incentivize improved reduction of future conditions and risks such as climate change, sea-level rise, urban flooding, and future development?
a. No answer at this time.
5) How could the CRS program better address the mitigation of repetitive loss/severe repetitive loss[14] properties and how could
a. The CRS program should have a staff member in every state compile a comprehensive list of resources available for helping communities perform buyouts. This would include tips and workshops for grants, lists of funding opportunities with deadlines, etc. The funds would only be available to communities that have strict regulations regarding substantive loss and improvement. Our community performed our first buyout and it was a learning process for everyone involved. We have interest in buying more properties with homes in the floodplain, but are limited financially. If there were additional resources, which would be one fewer thing we would have to devote research to.
6) How can the CRS program be modified, expanded, or streamlined to best incentivize participation by communities and flood insurance policyholders to become more resilient and lower their vulnerability to flood risk?
a. The first step in promoting CRS is to simplify it. There is no reason that staff should spend weeks and months just trying to learn and interpret the manual. Turnover in local government is relatively high. New employees who inherit this beast of a document are often overwhelmed.
7) How can the CRS program better incentivize floodplain management, risk management, and/or risk reduction efforts for communities through CRS discounts, grants, trainings, technical assistance or other means? Which efforts are most critical for the CRS program to support?
a. The CRS program should clearly present benefits of being in the program. There have to be ways that being a part of this program benefits the community directly or indirectly benefits our communities besides the small percentage in NFIP discounts. Highlight the availability (if any) of grants, discounts, or any other community benefit. The small savings in policies isn't enough, provide more incentives to encourage smarter growth.
8) What existing sources of data can
a. Many of the requirements involve paper letters, paper flyers, paper books, paper brochures, etc. Eliminate all this. Having an up-to-date and effective website with resources at citizen's fingertips is the answer.
9) The CRS program provides credits for flood risk reduction activities. Are there flood risk reduction activities that are not currently given credit within the CRS program that should be?
If so, what are they and why? Are there flood risk reduction activities that are currently given excessive credit within the CRS program than they should be given? If so, what are they and why? Should the CRS program provide a list of optional risk reduction activities for communities to choose from or a list of required risk reduction activities, and why?
a. Since no two communities are alike, there should be flexibility built into the CRS program. Some sections of the CRS appear to almost punish communities that have a low amount of floodplain or that lack the staffing to implement certain large and intense sections of the CRS. By adding optional places to make up points, it would give smaller communities ways to obtain a better ranking without having to spend weeks of staff time and potentially thousands of dollars on consultants.
10) What successful approaches have been taken by State, local, Tribal, and Territorial governments that the CRS program could leverage to better support community participation in the CRS program? In what ways could the CRS program better support States, Tribes, Territories and Regions, and flood control and water management districts to improve community participation in the program? What innovative changes could the CRS program make to be simpler for communities to join and maintain participation?
a. The CRS rating should be based on the ratio of flood losses to premiums paid. Communities that have achieved flood loss reductions would have higher ratings and lower premiums.
11) How could the CRS program provide better outreach to disadvantaged communities to encourage participation? How could the CRS program provide better outreach to households in disadvantaged communities to encourage participation in the NFIP?
a. Lower the federal costs of the CRS program by making the program simpler and pass those
12) In what ways could the CRS program facilitate collaboration across jurisdictional boundaries to support a community's ability to reduce flood risk? How could the CRS program be modified, expanded, or streamlined to allow for multi-jurisdictional collaboration efforts to receive credit under the CRS program?
a. Additional point opportunities can be given to communities that abut each other and both participate in the CRS program. Greater points, discounts, or grant opportunities can be given to groups of communities who abut. For example, if 4 abutting counties all participated in the CRS program and they had a combined average score of 7, they could qualify for a separate set of grant dollars.
13) What opportunities exist for the CRS program to better integrate with other entities and/or programs? For example, in what specific ways could the CRS program better work and integrate with State, local, Tribal, and Territorial programs, including but not limited to, floodplain management, emergency services, land use planning and building code administration capital improvement, transportation, redevelopment, pre- and post-disaster recovery, climate adaptation, hazard mitigation planning, watershed management, and/or wetlands, riparian, or environmental management programs? In what specific ways could the CRS program better work and integrate with Federal disaster assistance programs or Federal mitigation programs?
a. The simple answer is that communities love a solid source of money. If they can obtain funds through the CRS program, communities will likely follow. The issue with CRS is that it is 700 complicated pages of information that few have time to properly review, much less implement. Even the
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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0021-0001
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