Los Angeles County Public Works Department Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 24 -- The Los Angeles County Public Works Department 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 Sept. 22, 2021:

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Los Angeles County Public Works is the NFIP administrator for the unincorporated areas of Los Angeles County. There are approximately one million residents in the unincorporated areas, and approximately 4,700 residents and 1,700 structures in Special Flood Hazard Areas and approximately 45,500 residents and over 12,200 structures in the 0.2% annual chance flood area Los Angeles County joined the NFIP in 1980 and CRS in 1995. Los Angeles County currently has a CRS Class 7 rating. Los Angeles County recently completed its 5-year CRS Cycle Visit and review for a Classification Modification. It is anticipated Los Angeles County will have a Class 6 rating as of April 1, 2022.

Los Angeles County is a staunch supporter of the NFIP and of the goals of the CRS program in protecting lives and property and making communities better able to recover from flooding events and disasters. Los Angeles County's enclosed comments are made with a great deal of thought as a long-standing partner with FEMA and to assist FEMA in its efforts to improve the CRS program. The issues raised in FEMA's Questions 2, 3 and 4 are especially critical to us.

* We are concerned about the apparent imbalance between credits for a community's significant efforts in undertaking CRS activities and the penalties imposed for Elevation Certificate errors, especially for communities such as ours who process less than ten certificates annually.

* We believe the up-front costs of undertaking CRS activities and flood resiliency improvements, unintended challenges that may result from flood resiliency improvements, and the slow pace of re-designating mitigated repetitive loss/severe repetitive loss properties may be barriers to small and low-to moderate-income communities undertaking them.

* We are concerned about the potential adverse impacts resulting from FEMA acquiescing to the February 2021 petition from Natural Resources Defense Council and the Association of State Floodplain Managers adopt higher freeboard requirements than those of ASCE-24. This would undo years of effort by communities that adopted ACSE-24 in their building codes despite resistance from special interests, and residents who undertook at significant expense flood resiliency construction on their structures.

For any questions regarding these comments, please contact Ms. Patricia Wood at (626) 458-6131 or [email protected].

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

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