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Activity 310 - With less reliance on the Elevation Certificate for flood insurance, the Elevation Certificate form and the scrutiny it receives via CRS needs to be modified.
This certificate is complicated and is never completed correctly on the first submission, requiring multiple rounds of review by the community. This form needs to be simplified so that the directions are more easily understood and only includes the items necessary for compliance purposes.
If not being used for flood insurance, one suggestion would be to allow communities to develop their own forms (similar to having their own form for the floodplain use permit).
Also, the "gig list" used by CRS needs to be revised and updated and only the most important items included.
This will help focus on the most important items rather than items such as the community or panel number format. In addition, the penalty for having items wrong on the Elevation Certificate needs to be reviewed.
The current policy is especially burdensome for communities that only have a few elevation certificates per year.
It essentially results in requiring 100% accuracy rather than 90% accuracy. Given the complexity of completing the elevation certificate, this standard is set too high.
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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0021-0001
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