King County, Wash., Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 23 -- King County, Washington, 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. 20, 2021, and posted on Sept. 21, 2021:

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CRS Comments:

1. Keep CRS Resources (https://crsresources.org/) as the primary source of materials, training information, etc. for the CRS program. Frequent changes to FEMA's website often leave links unavailable, redirected to nowhere or moved entirely. Constantly changing URLs is not desirable for CRS communities who rely on this information and website being readily available.

2. Consider offering a financial support incentive to CRS communities for staffing/expenses related to the ongoing maintenance of the CRS program (similar to the CAP-SSSE funding support for the NFIP). Currently all of the financial incentives go to the individual policy holders rather than the CRS community. A financial incentive may help to draw more non-CRS communities and their elected officials to the program.

3. Provide more opportunities for CRS points for local programs that are "outside of the box". For example: integrated floodplain management programs that balance a multitude of floodplain uses for cumulative flood risk reduction (King County, WA); Resilient Tulsa (100 Resilient Cities Program) that addresses racial and social barriers while reducing flood and disaster risks; other CRS community mitigation activities, plans or programs that don't necessarily qualify for FMP (Element 512). Programmatic approaches to floodplain management that can demonstrate favorable outcomes and cumulative benefits to reducing flood related risks should be qualitatively reviewed against clear and documented big picture CRS / NFIP goals and values.

4. Currently CRS verification cycle visits are a "data dump" of verification documents at an assigned review time (particularly for top tier CRS communities - class 4 and better): Consider revising the system so that verification documentation gets submitted across the verification cycle year. For example: a Class 3 community with a cycle review date of October 15, 2022 would start submitting documentation for series 500 and 600 in spring, then 200 and 400 in summer and 300 in fall. This might make a more efficient timeframe for ISO to review/return comments and spread out the preparation time that many communities are often rushed to do just before their cycle review date.

5. Top tier CRS communities that follow the 3-year cycle verification must do more work in a shorter amount of time than the other communities. This is an undue burden on top tier communities and likely prevents other lower tier communities from wanting to move into a better class. Perhaps all communities should be on a more reasonable 5-year cycle, regardless of CRS class.

6. CRS credits should focus on the outcomes of a community's flood risk reduction programs. For instance, some CRS communities should be credited for the reduction in loss of life, not just property. There are several CRS programs in the nation where the losses to life due to flooding have been reduced to zero over the past few decades due to their flood awareness campaigns and flood control efforts. Please consider including the reduction to loss of life as a creditable measure of a floodplain management program as the purpose of the NFIP is to reduce losses to both life and property.

7. Stop raising the bar for CRS program class maintenance. Since CRS is supposed to be an incentive to go beyond the NFIP minimums, the rating system should remain static. Please consider adding new ideas as program improvements while allowing communities to maintain their class status without adding new prerequisites or requirements so frequently.

8. CRS insurance premium savings should be going to smaller, racially diverse, socially vulnerable communities in effort to address equity issues. Disadvantaged communities need considerable support to join CRS and maintain their programs. Perhaps a percentage of the top tier CRS community's premium savings could be equitably distributed to underserved NFIP and CRS communities so that they could benefit from both funding and program support.

9. Simplify the documentation process for CRS: Look for opportunities to simplify activity documentation to streamlined checklists. Overall, the CRS manual is too complicated.

10. Credit for outreach should be flexible to allow that different audiences need to receive messages in different ways so that traditionally marginalized communities and non-English speaking communities can be most effectively reached.

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

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