Duck, N.C., Senior Planner Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 23 -- Duck Senior Planner Sandy M. Cross, 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. 21, 2021:

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Thank you for the opportunity to provide comments on the Community Rating System. These comments are submitted on behalf of the Town of Duck which is a member of the Outer Banks Community Rating System User Group which consists of CRS coordinators from Currituck County, Dare County, the Town of Southern Shores, the Town of Kitty Hawk, the Town of Kill Devil Hills, the Town of Nags Head and the Town of Manteo. The Outer Banks area of North Carolina is located along the East Coast of the United States. The Town of Duck recently completed a five-year cycle review in late 2020 along with the other communities list above.

1. After taking two 4-day CRS courses at EMI and multiple online training sessions, the CRS manual is still very difficult and complex to understand and should be revised to be more user friendly. The volume of documents required is overwhelming and the scoring system should be easier to understand. Simple to use checklists should be provided to communities to ensure communities can respond with needed information. Scoring should be transparent with detailed scoring sheets and feedback from the technical reviewers on how submissions were graded. This should include those series activities where submissions were made but no points were credited. If we don't know how we were scored and/or why we were scored a certain way, we cannot work to improve that score.

2. The annual recertification process and the five-year cycle visits seem duplicative. Why do we need both? Much of the information required at the annual recertification is duplicated during the five-year cycle visit. Preparation for the five-year cycle review takes months of work. Small local governments rarely have a staff person dedicated solely to CRS administration; we all have other job responsibilities.

FEMA has a portal where documentation can be uploaded for reimbursements; perhaps a similar portal can be established for CRS documentation submissions with an alert system and help desk aspect?

3. The response time for verification of class ranking following a five-year cycle review is too lengthy. Dare County, the Town of Manteo, the Town of Duck, the Town of Kill Devil Hills, and the Town of Nags Head all had five-year cycle reviews in September 2020 within one week of each other's review. The Town of Duck, Manteo and Kill Devil Hills have been officially notified of their results with these results effective October 1, 2021. Dare County and Nags Head have only received unofficial notification with our results effective April 1, 2022. This is unfair and costly to the property owners in the Dare County and Nags Head jurisdictions, who will not reap the benefits of the increased class ratings. It should not take twelve months for documentation to be reviewed, scored, and finalized.

4. Local communities rarely have direct communication with the entire team of technical reviewers. The assigned CRS resource specialist is responsible for disseminating our information to several technical reviewers with whom we do not have direct communication. Since virtual meetings are now commonplace, local governments should be able to interact with the entire team of CRS reviewers to ensure our efforts and activities are fully understood and rated appropriately. CRS resource specialists should also provide updates to include when or if activities are sent to technical reviewers with appropriate contact information for that reviewer.

5. The Activity 330 outreach activities and scoring should be updated to reflect current use of social media to communicate information to property owners. The use of direct mailings is antiquated, costly, and ineffective. The use of social media platforms and e-group messaging accomplishes the same goal of communicating risks to property owners, more efficiently from both a time and cost perspective.

6. The 90% correctness requirement for elevation certificates seems onerous and an automatic retrograde to a class 9 is unnecessarily punitive for documents which will no longer be mandated by the NFIP. With the release of RR2.0., there is a clear disconnect between the NFIP and the CRS program that should be looked into. Additionally, correctness should be more lenient for actual data mistakes rather than minutia such as a missing zip code or expired form when the relevant data is present and accurate. Perhaps consider some "smart" form features to limit the minor errors and omissions like missed check boxes or empty answers.

7. There is currently no noticeable credit for resiliency efforts or regulatory initiatives that apply to areas outside of the special flood hazards areas. Dare County and the municipalities of Duck, Southern Shores, Kitty Hawk, Kill Devil Hills, Nags Head and Manteo all adopted a local elevation standard in 2020 establishing a local regulatory flood level and other floodplain regulations for Shaded X and X zone properties. Under the 2020 five-year cycle reviews, we were each awarded only 25 points for these higher regulatory standards. We were advised that the technical reviewers needed impact adjustment maps to document the application of this local elevation standard. Impact adjustment maps are difficult for small communities without GIS capabilities to produce. While we were able to provide such maps, the current CRS program has no methodology by which to score efforts outside of the SFHA. Section 112 of the 2017 CRS manual states the goal of the CRS program is to recognize, encourage, and reward community activities that go beyond the minimum National Flood Insurance Program requirements. A scoring system that fully recognizes these goals needs to be implemented. The implementation of local elevation standards outside of the SFHA exemplify the goals of the CRS program. This type of initiative should also be applauded for improved reduction of future conditions and uncertain risks such as climate change and sea-level rise.

8. Contracted CRS reviewers should be located in or near, and be familiar with the region which they serve. Discussions and advice would be more productive and valuable to the communities if the reviewers were mildly familiar with the region.

Again, thank you for the opportunity to participate in the review of the CRS program. It is our hope that these comments will result in revisions to the CRS program motivating participating and new communities to continue efforts for flood insurance advocacy and resiliency within their communities.

Sincerely,

Sandy M. Cross, CFM

Senior Planner

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

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