James City County Virginia Section Chief Issues Public Comment on FEMA Notice

WASHINGTON, Oct. 28 -- Michael Woolson, section chief for resource protection at the James City County Virginia, Williamsburg, 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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Thank you for the opportunity to provide comments on the Community Rating System. These comments are submitted by James City County Virginia. We are part of the Coastal Virginia CRS Workgroup, a workgroup that provides assistance and expertise in floodplain management and flood risk reduction best practices, and have recently completed the five-year cycle review and recently received our annual recertification.

1. The CRS Program and regulations are complex and the documentation requirements are time-consuming. They should be revised to be more user friendly in terms of understanding the scoring system and the volume of required documents. For several activities, the total points available does not justify the staff time that would be spent. For other activities, the tiered approach to points earned helps to justify a high standard to our local leaders.

2. Our last five-year cycle visit was far longer than stated in the CRS Manual and delayed the premium reductions offered to our citizens as a Class 5 community, as previously we were a Class 7 community. Preparation of the five-year cycle visit takes many months of work. James City County does not have a staff person solely dedicated to CRS program administration. The Program takes significant time and energy to administer.

3. In order to promote and/or incentivize the improved reduction of future conditions such as sea-level rise and urban flooding, a separate Future Conditions activity should be created to award points for specific future condition scenarios. Specifically, points should be achieved for the program policy and then additional points achieved for the execution of the policy.

4. To better address the mitigation efforts of repetitive loss/severe repetitive loss properties, access to the RL/SRL lists is required. The current process is time-consuming and onerous.

5. The technical assistance and training are critical issues for the County to maintain the CRS class rating as staff retention issues arise and the knowledge base leaves the County. This helps to provide a more stable transition in the CRS Program administration. Access to and continuation of technical assistance and training opportunities is critical.

6. Flood risk reduction activities should be more clearly credited in Activity 530, Flood Protection, by simplifying this section and providing more flexibility in alternative actions. Expanding the credit to the 500-year floodplain would help to incentivize our community for mitigation in the future floodplain due to the effects of sea-level rise.

Thank you for the opportunity to participate in the review of the CRS program. I am hopeful these comments will result in effective revision to the CRS program as we continue our efforts for flood risk reduction and resiliency in our community.

Sincerely,

Michael Woolson, PLA, CFM

Section Chief, Resource Protection

James City County, Virginia

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

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