* * *
Thank you for the opportunity to provide comments on the Community Rating System. These comments are submitted on behalf of the
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.
3. The response time for verification of class ranking following a five-year cycle review is too lengthy.
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.
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.
* * *
The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0021-0001
TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact