Greater Edwards Aquifer Alliance Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 28 -- Annalisa Peace, executive director at the Greater Edwards Aquifer Alliance, San Antonio, Texas, 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 written on Sept. 22, 2021, and posted on Sept. 27, 2021:

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Thank you for the opportunity to submit these comments and recommendations on behalf of the fifty-four member groups of the Greater Edwards Aquifer Alliance (GEAA). GEAA unites fifty-five diverse member organizations to advocate preservation of our ground and surface water resources in twenty-two counties within central and south Texas, including the Texas Hill Country.

Most of our service area is within the area known as Flash Flood Alley, a region of central Texas designated by the National Weather Service as the most flash flood prone region in North America, leading in the number of flash and river flooding-related deaths annually. For this reason, we are devoting significant resources to the Texas Water Development Board's Regional Flood Planning Process. GEAA staff serves representing the environment on the Guadalupe and San Antonio river watersheds Regional Flood Planning Groups.

GEAA staff, expert advisors, and member group leaders all agree that nature based systems, with their co-benefits, need to play a large role in flood risk reduction. We recommend a point structure that accords ratings that encourage consideration of more options on how to reduce flood risks while creating greater resiliency. Even though land preservation within the floodplain is a current option, managing by watershed could easily identify strategically located, undeveloped land outside of the floodplain and should be considered.

It is also recommended that consideration be given for stream and riparian restoration efforts and ensuring that the natural system functioning of floodplains are protected. That is, if credit is given for floodplain preservation it must be tied to land development regulations.

If regulations allow discharges that cause degradation to preserved floodplains, they will no longer provide the resiliency needed to reduce flood risks. Floodplain degradation leads to increased flood risks in urban areas and downstream. The option to "Regulate new development throughout the watershed to ensure that post-development runoff is no greater than pre-development runoff." is crucial and, coupled with preservation and restoration, needs to be a priority.

GEAA will be promoting the use of the Federal Emergency Management Agency's Community Rating System under the National Flood Insurance Program and asking that consideration be given to increase options outside the floodplain and increase points for incorporating nature based/green infrastructure flood mitigation solutions, including the benefits of vegetation and soil management practices as stated in the attached comments from the Council for Healthy Food Systems.

View attachment at: https://downloads.regulations.gov/FEMA-2021-0021-0153/attachment_1.pdf

Respectfully,

Annalisa Peace

Executive Director

Greater Edwards Aquifer Alliance

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

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