Miami-Dade County, Fla., Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 24 -- Miami-Dade County, 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 Sept. 23, 2021:

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1. What are the strengths of the current CRS program? What components of the program are currently working well and why? https://www.federalregister.gov/d/2021-18167/p-46

The strength of the CRS Program lies in creating a path for building a solid flood protection program, through the series of activities that, if conducted, will educate the communities on how to best elevate the flood protection levels of service of the community.

Here is a breakdown of our experience in implementing the program:

Public Information Activities (300 Series): all components in this series have been effective, except for the Flood Insurance Promotion.

While we strongly believe that we should promote the purchase of flood insurance, the way the activity 370 is structured does not account for purchase of private flood insurance policies, which are common in condominiums and high-rises, which have high property values. Additionally, the number of points provided under this activity is not proportional to the level of effort required to conduct the coverage assessment, offering only 110 points. Manual shows that only 4% of the communities were credited in this activity, with an average of 39 points.

400 Series: Mapping and Regulations: this is the portion of the CRS Program that we consider most helpful.

500 Series: Flood Damage Reduction Activities: the 500 series contain elements that tied up to the elements of the 400 series. We consider this series very helpful in creating an effective program.

600 Series: Warning and Response: The Activity 610 is considered very effective, however the Activities 620 (Levees) and 630 (Dams) were not implemented in our area since we do not have any levees or dams. Differences in geography and geology condition the engineering solutions for flood protection.

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

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