Key West, Fla., Issues Public Comment on FEMA Notice

WASHINGTON, Oct. 23 -- The city of Key West, Florida, 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. 19, 2021:

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* 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. - Regulations Administration (RA)

- 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 State of Florida for CFMs to visit construction sites to examine floodplain compliance measures.

* Absent consent of the local Chief Building Official and having a licensed building inspector accompany a CFM, authority to inspect is non-existent.

* 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 Florida Keys; both of which happened to be within the Key West city limits.

- 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.

* Building Height Exceptions (New credit)

* 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

Scott Fraser, Floodplain Administrator, 305-923-4964 floodplain@cityofkeywest-fl.gov

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

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