Fors Marsh Group Issues Public Comment on FEMA Notice

WASHINGTON, Oct. 28 -- Fors Marsh Group LLC, Arlington, Virginia, 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 Oct. 25, 2021:

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Introduction

Fors Marsh Group, LLC (FMG) is pleased to respond to the request for information from the Federal Emergency Management Agency (FEMA) to receive input on transforming the Community Rating System (CRS) program to better align with the current understanding of flood risk and flood approaches and to incentivize communities to not only manage but also lower their flood risk through floodplain management initiatives.

FMG is a leading research and evaluation partner with several federal agencies including FEMA's Office of National Assessments and Integration (ONAI) and Individual and Community Preparedness Division (ICPD). Drawing on our expertise in preparedness and flood mitigation, we suggest five recommendations for transforming CRS with an emphasis on evaluation and evidence-building. Our recommendations are aligned with the Foundations for Evidence-Based Policymaking Act of 2018 and will contribute to FEMA's larger goals for evidence-building.

* Recommendation 1: Create a CRS learning agenda and annual evaluation plan.

* Recommendation 2: Develop evidence-based flood risk management practice guides to help floodplain managers and CRS coordinators determine how best to manage current flood risks and reduce future flood risks.

* Recommendation 3: Bolster CRS participation and make participation more equitable by reducing administrative burdens and improving management systems.

* Recommendation 4: Conduct behavioral research studies to determine if increases in flood insurance premium discounts result in an increase in CRS participation.

* Recommendation 5: Provide additional incentives to CRS communities to not build or reside in areas with high flood risk.

Recommendation 1: Create a CRS learning agenda and annual evaluation plan (Question #2).

Under the Foundations for Evidence-Based Policymaking Act (Evidence Act), CFO Act agencies are developing strategies and plans to build evidence about agency programs and initiatives. Key among these are learning agendas and annual evaluation plans. A learning agenda articulates the key research questions, both short and long term, that must be answered to achieve programmatic goals and desired outcomes. An annual evaluation plan describes the planned research and evaluation activities an agency or component will undertake to address the questions in the learning agenda. A learning agenda, when combined with an evaluation plan, will build evidence to help ensure that federal programs meet their goals and objectives.

FEMA is currently developing an agency-wide learning agenda and capacity assessment as required by the Evidence Act. We recommend CRS program staff take a parallel step and identify the critical learning questions and evaluation strategies to answer these questions. As a first step, FEMA should develop a CRS program logic model. Logic models describe a program's anticipated theory of action and the relationships between program inputs, activities, outputs, and outcomes. Identifying these components can reveal gaps in knowledge about how programs are intended to operate and the types of outcomes that are expected if a program is functioning as expected. A logic model is the first step in measuring and evaluating a program because it will help identify research questions, the data required to answer the research questions, and analytic methods.

A logic model for the CRS program would serve as a North Star to guide strategies for reducing flood risk and flood losses. We recommend FEMA elicit input from CRS stakeholders (e.g., academic community, nongovernmental organizations, state and local floodplain managers) about the inputs, activities, and outputs that are hypothesized to affect these outcomes, as well as any other outcomes identified.

In 2019, under contract to ONAI, FMG developed a logic model for the Homeland Security Grant Program (HSGP), which has subsequently directed HSGP research and evaluation activities. In a similar fashion, FEMA can use a logic model to understand the relationship between desired outcomes and its various activities, specifically for the CRS program, which are less well-defined.

After developing a logic model for the CRS program, FEMA should then create its own learning agenda and an associated annual evaluation plan. Whereas the learning agenda will identify priority research questions on the CRS program and potential research strategies, the annual evaluation plan will identify the priority research question(s) CRS program staff seek to answer in a given year and will outline methods for answering the priority question(s) as well as potential problems that may arise during the research and evaluation process. Through the consistent evaluation and reporting on the CRS program, FEMA can drive meaningful progress to improve the program that is both evidence-informed and transparent.

FMG recently worked with FEMA's ONAI to facilitate a collaborative process to develop a research and evaluation plan. Specifically, in 2020, FMG worked with ONAI to develop the HSGP Grant Effectiveness Data Roadmap, which includes a learning agenda that identifies specific research questions that, when answered, would provide necessary evidence to inform grant investments and improve program outcomes. In addition to the learning agenda, the HSGP Grant Effectiveness Data Roadmap articulated the ideal state of grant effectiveness evaluation, discussed the associated capacity, cultural, data, and technical challenges associated with achieving it, and proposed solutions to begin addressing those challenges. This process could be replicated with the CRS program.

Recommendation 2: Develop evidence-based flood risk management practice guides to help floodplain managers and CRS coordinators determine how best to manage current flood risks and reduce future flood risks (Questions #4 and #8)

Communities must not only manage current flood risks but also consider how they can reduce future flood risks. To do so, local floodplain managers and CRS coordinators need succinct information on what mitigation measures are most effective when it comes to reducing flood risks and flood losses. As a result, we recommend FEMA develop evidence-based practice guides that synthesize programs and practices known to be effective in reducing flood risks and flood losses. Local floodplain managers and CRS coordinators would be the primary users of these practice guides.

Practice guides combine research evidence with expert judgment to identify the most effective practices to achieve desired outcomes. They are developed by (1) creating evidence standards, (2) reviewing the relevant research literature against the standards, and (3) engaging experts to review the evidence and describe how the most effective practices can successfully be implemented. Evidence standards are criteria used to assess the strength and credibility of research designs. Not all research is created equally-some research studies are more rigorous than other studies and we can have greater confidence in the results from more rigorous research designs. Evidence standards are important because they establish a common frame of reference to measure effectiveness and a guidepost for evaluation activities. For CRS, the evidence standards would be designed to reflect the state of knowledge within the field of flood mitigation. For example, evidence standards may be defined as "emergent, developing, mature," with each level clearly defined and illustrated with examples.

Once the evidence standards have been defined, the research evidence on particular topics in flood mitigation would be reviewed to identify the policies and practices that have the strongest evidence of effectiveness. For example, if the topic of public/private partnerships were of interest, the research review might examine the evidence of effectiveness on environmental impact bonds as a policy approach. Once the evidence has been reviewed and assessed based on the strength of evidence, subject matter experts in flood mitigation policies and practices would review it and describe how the policy or practice can be implemented. In this way, practice guides bridge two types of evidence - evidence from research studies and evidence generated by subject matter experts. This combination is particularly powerful for guiding policy because it is grounded in both research and experiences about implementation. Moreover, the subject matter experts lend credibility to the practices that are described, increasing the likelihood of uptake among those charged with designing and implementing flood mitigation programs.

Recommendation 3: Bolster CRS participation and make participation more equitable by reducing administrative burdens and improving management systems (Questions #2 & #3)

Studies show that a lack of resources (e.g., staff, funding, and time) is the primary factor inhibiting community participation in the CRS./1

As a result, communities with lower floodplain management budgets and organizational capacity are less likely to participate in the program, thus making the program inequitable. Indeed, communities with fewer staff and financial resources are unable to participate in the CRS simply because they do not have the capacity to deal with the paperwork required for participation. Additionally, research demonstrates CRS participation is lower in areas with greater minority populations and higher unemployment, poverty, and crime rates./2,/3

This provides additional evidence that the CRS program is not equitable. FEMA is well positioned to address equity concerns related to the CRS given the Biden Administration's recent Executive Order on diversity, equity, and inclusion as well as FEMA's current annual planning guidance that outlines a larger equity agenda for the agency.

To participate in the CRS, communities must have and maintain strong documentation, indicating they have successfully implemented flood mitigation activities creditable under the CRS program. To bolster CRS participation and make participation more equitable, FEMA should ease administrative burdens by reducing the amount paperwork to gather that is required for initial and continued participation in the program. This can be achieved through improved management systems that help local communities organize and maintain their flood mitigation documentation. The development of this new management system should be a collaborative process that involves key stakeholders, including CRS program staff, Information Technology (IT) experts, state floodplain managers, and local floodplain managers and CRS coordinators.

To develop this new management system, FEMA should conduct a needs assessment that elicits feedback from the key stakeholders. This needs assessment will help FEMA better understand the obstacles hindering communities' ability to participate in the CRS program. For example, this needs assessment will help FEMA determine whether data and document management and reporting at the local level is the primary barrier to participation or if some other factor such as complicated paperwork is the primary barrier. This needs assessment should also identify actionable ways to address barriers to participation, such as providing additional technical assistance. The inclusion of these stakeholders in the research process will help ensure improvements are both functional and effective at reducing the administrative burdens associated with CRS participation. Doing so will better allow communities with lower fiscal and organizational capacity to participate in the CRS.

Additionally, CRS program staff should consider how ONAI is currently addressing administrative burdens through their HSGP Pilot Project. Through this pilot project, FMG is helping ONAI test modifications to data collection processes with the goal of minimizing the burden on grant recipients as well as improving the usefulness of the data. CRS program staff should consider a similar style of project that uses focus groups and/or interviews to collect feedback on barriers to CRS participation.

Recommendation 4: Conduct behavioral research studies to determine if increases in flood insurance premiums discounts results in an increase in CRS participation (Question #7).

A handful of studies demonstrate that communities that participate in the CRS experience fewer flood losses flood losses, measured as less property damage,/4,/5,/6 property and crop damage,/7 flood claims,/8,/9 and flood casualties./10

Given these encouraging findings, there is a clear interest in increasing CRS participation.

Additionally, studies indicate reductions in flood insurance premiums is the primary reason for initial and continued participation in the CRS program./11

Given that most communities participating in the CRS are in between a Class 9 and a Class 7, a viable strategy to increase CRS participation is to make the incentive of participating in the CRS (e.g., reduced flood insurance premiums) more enticing. This can be done through a modest increase in discounts to flood insurance premiums. FEMA should conduct studies to determine at what flood insurance discount percentage non-CRS communities will decide to participate in the program. This would involve developing a study that tests norms around participation.

Specifically, FEMA should employ experimental and quasi-experimental research designs to determine if increases in reductions in flood insurance premiums entice NFIP participating communities that are able but do not currently participate in the CRS to participate, and if so, at what level of discount (e.g., 10%, 15%, 20%, etc.). This type of study should be included in the CRS-focused learning agenda and annual evaluation plan described in Recommendation 1.

Recommendation 5: Provide additional incentives to CRS communities to not build or reside in areas with high flood risk (Question #9).

Research indicates the CRS program may encourage development in flood-prone areas./12

Research has also shown that structural mitigation measures such as levees may provide a false sense of security to residents, resulting in a lack of a preparedness./13

To manage current flood risks and minimize future flood risks, FEMA should further incentivize CRS communities to implement flood mitigation measures that are known to be effective at reducing flood risks and flood losses. One such measure is pursuing an avoidance strategy whereby communities do not build in areas with a high flood risk. Indeed, a growing body of research underscores the value of open space protection./14,/15

With that, we recommend FEMA consider two approaches to incentivize communities to engage in open space protection: (1) provide additional CRS credit points to both the open space protection activity as well as the acquisition and relocation activity; (2) and offer grants specific to CRS communities to engage in both the open space protection activity as well as the acquisition and relocation activity. The latter could also generate additional participation in the CRS program as non-CRS communities may want to take advantage of the additional grant opportunities.

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Footnotes:

1/ Sadiq, A. A., Tyler, J., & Noonan, D. (2020). Participation and non-participation in FEMA's Community Rating System (CRS) program: Insights from CRS coordinators and floodplain managers. International Journal of Disaster Risk Reduction, 48, 101574.

2/ Landry, C. E., & Li, J. (2012). Participation in the community rating system of NFIP: Empirical analysis of North Carolina counties. Natural Hazards Review, 13(3), 205-220.

3/ Li, J., & Landry, C. E. (2018). Flood risk, local hazard mitigation, and the community rating system of the national flood insurance program. Land Economics, 94(2), 175-198.

4/ Brody, S. D., Zahran, S., Highfield, W. E., Grover, H., & Vedlitz, A. (2008). Identifying the impact of the built environment on flood damage in Texas. Disasters, 32(1), 1-18.

5/ Brody, S. D., Zahran, S., Maghelal, P., Grover, H., & Highfield, W. E. (2007). The rising costs of floods: Examining the impact of planning and development decisions on property damage in Florida. Journal of the American Planning Association, 73(3), 330-345.

6/ Davlasheridze, M. (2013). Hurricane disaster impacts, vulnerability and adaptation: Evidence from US coastal economy.

7/ Kim, H. (2015). Exploring the role of community capacity and planning effort in disaster risk reduction and environmental sustainability: Spatio-temporal vulnerability and resiliency perspectives (Doctoral dissertation, The University of Wisconsin-Madison).

8/ Asche, E. A. (2013). The effect of flood risk on housing choices and community hazard mitigation. University of California, Santa Barbara.

9/ Highfield, W. E., & Brody, S. D. (2017). Determining the effects of the FEMA Community Rating System program on flood losses in the United States. International journal of disaster risk reduction, 21, 396-404.

10/ Zahran, S., Brody, S. D., Peacock, W. G., Vedlitz, A., & Grover, H. (2008). Social vulnerability and the natural and built environment: a model of flood casualties in Texas. Disasters, 32(4), 537-560.

11/ Sadiq, A. A., Tyler, J., & Noonan, D. (2020). Participation and non-participation in FEMA's Community Rating System (CRS) program: Insights from CRS coordinators and floodplain managers. International Journal of Disaster Risk Reduction, 48, 101574.

12/ Brody, S. D., Zahran, S., Maghelal, P., Grover, H., & Highfield, W. E. (2007). The rising costs of floods: Examining the impact of planning and development decisions on property damage in Florida. Journal of the American Planning Association, 73(3), 330-345.

13/ Burby, R. J. (2006). Hurricane Katrina and the paradoxes of government disaster policy: Bringing about wise governmental decisions for hazardous areas. The Annals of the American Academy of Political and Social Science, 604(1), 171-191.

14/ Brody, S. D., & Highfield, W. E. (2013). Open space protection and flood mitigation: A national study. Land Use Policy, 32, 89-95.

15/ Highfield, W. E., & Brody, S. D. (2013). Evaluating the effectiveness of local mitigation activities in reducing flood losses. Natural Hazards Review, 14(4), 229-236.

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

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