Key West, Fla., Issues Public Comment on FEMA Notice
* * *
* 300 Public Information
- 310 Elevation Certificates
* Provide credit for the offsite, online, public access to all floodplain related flood certificates (ECs, floodproofing, V-zone certs, nonconversion agreements etc.).
* Access to the actual downloadable documents, rather than simply information noting that such exists.
* Off-site, off-system storage of flood certificates.
* Flood certificates
- Our city servers were hacked with ransomware with the side-by-side servers compromised as well. Had our flood certs not been digitally stored separately, those would have been lost as well.
* Construction permitting files
- Equally as critical is ensuring the off-site off-system construction permitting documents are backed-up separately. During our hack, the permitting and backup permitting documents were lost because both servers were on the same system.
* 420 Higher Regulatory Standards
- 432.q. -
- Recommendation: Allow new and significant credit for states/communities authorizing CFMs to conduct site inspections for floodplain management concerns.
- Presently, there's no legal authority within the
* Absent consent of the local Chief
* Examples:
* Floodproofing projects often require mid-phase inspections to ensure walls are properly sealed before being covered.
* Details described on Elevation Certificates may need to be field verified with site visits.
* Flood venting often needs inspections to ensure documentation of the type, model, quantity and placement.
* Ensuring permitted below BFE storage/parking areas have limited construction precluding habitation.
* Scope of work being performed was within the work permitted and compliant with Substantial Improvement thresholds.
* 442c - Benchmark Maintenance (BMM)
An inability to disqualify benchmarks that can't be recovered and too small a CORS area requirements combine eliminate any possibility of obtaining this credit. Advances in technology now allow for much greater CORS access, but this CRS credit does not.
- Recommendation(s):
* Benchmarks
* Allow for the exemption of benchmarks no longer in active use that can't/won't be recovered.
* CORS
* Reduce number of CORS to two within 30 miles, or
* Three within 150 miles, or
- Benchmarks
* No longer critical to surveyors, so there's little interest in maintaining them.
* When even a single benchmark can't be recovered - destroyed, demolished - there's no mechanism within CRS to receive any BMM credit for the remaining benchmarks.
- CORS site
* Requiring three CORS within 30 miles is too stringent and unnecessary. Two are satisfactory, and others can be accessed from greater distances.
* CORS now cover much larger areas.
* There are only two CORS sites within the entire
- CHIN
- FLKW
* MTNT is located within 166 miles
* Additional CORS within the same operational radius include: NAPL, FLF1, N300, ZMA1, LAUD, FMYR.
- Two within 30 miles and one within 150 miles.
* 500 Flood Damage Reduction Activities
- 510 Floodplain Management Planning (FMP)
* Step 5 Assess the problem
* C. Digitalized damage assessment
- Recommendation: Add significant points for spatially (GIS) recorded damage assessments.
*
* Recommendation: Create credit for allowing flood mitigation exceptions that'd otherwise be prohibited.
* Communities with building height restrictions limit flood mitigation elevation considerations. Allowing building height exceptions within the SFHA for such mitigation would be beneficial.
- In our community, the building height exception allows for exceeding the restriction on the top by the elevation on the bottom by a maximum of four feet above BFE. Yet there's no CRS credit for such.
* 430 Higher Regulatory Standards
- 432.d. Cumulative Substantial Improvements (CSI)
* 5-year/10-year cumulative credits
* These credit values are so low and the public and political grief so high, we abandoned such credits during the last full recertification.
end
* * *
The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0021-0001
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