National Association of Flood & Stormwater Management Agencies Issues Public Comment on FEMA Notice

WASHINGTON, Oct. 28 -- The National Association of Flood and Stormwater Management Agencies 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. 25, 2021:

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Thank you for the opportunity to provide input on the CRS program.

The National Association of Flood and Stormwater Management Agencies (NAFSMA), founded in 1978, is an organization of public agencies whose function is the protection of lives, property and economic activity from the adverse impacts of storm and flood waters. NAFSMA member agencies either belong to the National Flood Insurance Program (NFIP) or work with communities that belong to the NFIP. Our mission for over 40 years has been to advocate public policy and encourage technologies in watershed management that focus on flood protection, floodplain and stormwater management.

NAFSMA continues to support the CRS program and its encouragement to communities to go beyond the NFIP's minimum requirements by providing discounts to flood insurance policyholders located within those communities.

Floodplains usually extend across multiple cities or even counties and the current CRS program does not adequately recognize or reward regional coordination on flood risk reduction. The CRS program is administered through public agencies with land use authority, whereas flood risk reduction efforts may be administered by a separate regional flood risk reduction agency. The CRS model creates inefficiencies and undue burden on both the land use authority and flood risk reduction agencies by not integrating both agencies into the process. CRS should be encouraging regional coordination efforts that reduce flood risk and the sharing of resources across floodplains.

An example of this is the City of San Antonio's reliance on the San Antonio River Authority (SARA) for floodplain mapping, regional watershed master planning and some outreach around flood risk. Additional work is created when requiring both agencies to track and coordinate these efforts for separate reporting to FEMA. In Maricopa County, Arizona, where the cities administer the CRS program, better efficiencies, coordination, and use of resources could be achieved if the CRS program scored the efforts of a local Flood Control District and automatically take these results into consideration when scoring the local CRS communities. Smaller cities, with less resources, could benefit from this regional approach. NAFSMA encourages FEMA to evaluate how the CRS program can better integrate recognition and reporting of regional floodplain management initiatives into the program.

The CRS program should also recognize the regional differences in how flood risk reduction programs are implemented and incorporate flexibility into activities to reflect this difference to allow public agencies to best serve their community. For example, mitigation activities and outreach messaging are very different between communities in the arid southwest, which receive minimal rainfall each year, and the southeastern part of the country where communities experience more frequent storms with larger rainfall volumes.

NAFSMA also believes that community level discounts and best practice encouragement could be expanded by providing additional discounts to the most compliant policy holders at a structure specific level. Not all of the risk exposure in a single community is the same because of individual floodplain management practices being undertaken in various locations within a community to meet distinct challenges. Many structures that were built prior to these policies and actions being in place at the community level currently reap the highest discounts compared to contemporary structures outside the floodplain. The structures that are being built under the current CRS rating policies should be afforded the largest discounts as an incentive for the continued participation and compliance with program.

In an effort to streamline submittal requirements, NAFSMA offers to assist FEMA in efforts to reduce the level of documentation associated with CRS and in the identification of common information required by different federal programs. In addition, NAFSMA encourages CRS to evaluate which Activities and Elements of the program are reducing community risk and which ones have negligible impact. Removing the Activities and Elements from the program that have little impact could reduce the complexity of the program and make it easier for smaller and underserved jurisdictions to participate.

The issue of the houseless population in the United States continues to grow and the impact on life safety and flood risk reduction infrastructure performance and floodplains are a significant concern among local agencies. Houseless populations continue to camp and congregate in floodplains, jeopardizing their safety, making operation and maintenance a challenge, and in some cases damaging the structures and leaving debris that inhibits the function of the system. This creates a dangerous situation not only for the houseless population in the area, but for those residents and businesses relying on flood control works and floodplains to reduce flood risks.

NAFSMA encourages FEMA through the CRS program to recognize this issue and provide credits to communities that are proactively working with houseless encampments to find safe areas for their camps. We urge FEMA to coordinate with other agencies including the US Interagency Council on Homelessness to identify solutions to the underlying problems of homelessness and to develop best management practices to help local agencies deal with the ongoing difficulties of maintaining floodplains with encampments.

NAFSMA supports the intent of Risk Rating 2.0 to create a more equitable and fiscally resilient program with premiums that better reflect each property's individual flood risk. To ensure successful implementation of this program FEMA needs to engage more with local floodplain managers. NAFSMA requests more clarity around how Risk Rating 2.0 will interact with CRS and the discounts being offered. Specifically, how local community's mitigation projects will impact both CRS and flood insurance premiums.

CRS should provide greater credit for capital projects that lower a community's flood risk. Many NAFSMA members construct capital projects that benefit buildings within the SFHA and outside the SFHA. These projects can also lower the flood risk for repetitive loss properties. We note that Activity 530 Flood Protection has one of the lowest percentage of communities obtaining credited (2017 Manual). Since the NFIP reports that a significant percentage of claims are from outside the SFHA, we believe that this Activity needs to be revised and should be promoted more. We feel that many communities are not fully taking advantage of the credit available in Activity 530. Some members report that when a capital project removes the SFHA, the area mitigated is no longer eligible for credit under Activity 530. We feel that CRS should recognize all capital projects that reduce flood risk and the benefits they provide to communities and the NFIP.

Communications requirements in the current CRS manual also merit review. Many of NAFSMA's members conduct multiple region-wide outreach projects on flood risk and flood safety. Unfortunately, because of the very prescriptive process required by CRS, local communities can't obtain additional credit for having a Program for Public Information (PPI). NAFSMA believes that the focus should be on the outreach being done and not on the process to develop the outreach. Our members would like to see greater flexibility in the development of a PPI. NAFSMA recommends that the outreach requirements be reviewed and updated to also encourage the use of newer approaches available through social media that can reach different audiences in the community, can be conducted more frequently, and be appropriate for the flooding situation.

Other Activities that NAFSMA feels that need a major revision are 610 Flood Warning and Response, 620 Levees, and 630 Dams. Many NAFSMA members take the lead on these Activities for their service areas and client communities. The current CRS practice only credits communities if they can demonstrate fulfilment of all of the elements within an Activity. This approach is very regressive and doesn't recognize the existing efforts being done that lower the flood risk within a community. Instead, CRS should take an approach that rewards communities for their current efforts and encourages them to do more. Communities should be able to receive credit even when their actions only meet the criteria for 1 or 2 elements.

In general, NAFSMA encourages FEMA to evaluate how criteria for credits in the CRS program are awarded and can be used to incentivize the development of regional efforts to improve flood resiliency in communities. Too often communities are having to change their processes in order to align with CRS requirements, and there is no corresponding increase in effectiveness or usefulness of the final product.

NAFSMA appreciates the opportunity to comment on this important program. Please contact NAFSMA Executive Director Susan Gilson at (202) 289-8625 or [email protected] with questions.

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

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