National Center for Appropriate Technology Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 24 -- Steve Thompson, executive director at the National Center for Appropriate Technology, Butte, Montana, 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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The National Center for Appropriate Technology (NCAT) appreciates the opportunity to provide comments on the National Flood Insurance Program's Community Rating System. NCAT has been promoting sustainable living for over 45 years. Established in 1976 and based in Montana, we have field offices in 10 states. We are a national nonprofit with a mission of helping people build resilient communities through local and sustainable solutions that reduce poverty, strengthen self-reliance, and protect natural resources. Our educational, training and technical assistance programs are focused on sustainable agriculture, clean energy solutions, and community resilience.

As climate change drives increasing intensity of storms, it is important for the CRS to consider land-use patterns in upland areas. Traditional concepts of "floodplains" no longer are sufficient for evaluating flood risk, as flooding increasingly impacts developments outside of traditional floodplains. Community solutions - and FEMA incentives - to reduce risk must look beyond traditional floodplain management ordinances that regulate development in the floodplain.

Our comments are focused on the potential for appropriate agricultural land-use practices to reduce downstream risks of flooding for community infrastructure, homes, and commercial developments. While there are a variety of farm practices that will provide this benefit - including wetland restoration, agroforestry, strategic swales, and perennial cropping systems - our comments will focus on the broad array of practices associated with soil health.

NCAT works with farmers and government agencies to promote soil health practices that serve to capture and infiltrate rainwater through programs such as our Soil for Water Initiative. Until recently, we have focused on the on-farm benefits of these practices. However, we have come to appreciate the off-farm benefits of these practices for society at large, particularly for mitigating downstream flood potential.

We recommend that FEMA add points to the CRS for the use of soil health-building practices on farms and ranches, including: cover crops, perennials, chemical-free no-till and reduced till, use of soil amendments that improve soil microbiology (such as compost and compost teas), and managed rotational grazing.

Among the well-documented benefits of soil health are mitigating flood waters, flood damage, and the impacts of drought. There's growing evidence that how the land is managed can make a major difference on how much runoff leaves the land after a rainfall event. During a rainfall event, healthy soil management can make the difference between infiltration of 1 inch of rain taking over 31 minutes (regularly tilled cropland) versus 7 minutes (regular "open space" pasture land) versus 10.1 seconds in rotationally grazed (healthy soil) land./1

Healthy soils not only absorb water quickly, they can absorb a lot more of it. A 2005 study by the Natural Resource Defense Council (NRDC) found that for every additional 1% of organic matter in farm soils, an additional 10,000 gallons of rainwater were captured and infiltrated - per acre./2

Others have estimated more than 25,000 gallons of water retention for every 1% organic matter. The implications of building healthier farm soils through conservation practices such as no-till, cover crops, soil amendments and pastured livestock/rotational grazing are potentially huge for flood mitigation, especially when aggregated across a significant percentage of a watershed./3,/4,/5

These practices reduce floodwaters where they hit the ground, thereby minimizing damaging flood flows that cause erosion, siltation, damage to bridges and culverts, retaining walls and dams, and flooding in downstream communities.

It's worth noting that the same farming and ranching methods that help capture floodwaters and reduce the impact of flooding also serve to increase drought resilience and support aquifer recharge.

Adding community rating points for the use of on-farm cover cropping, perennials, no-till, soil amendments and managed livestock grazing will create important incentives for communities to reward farmers for building healthier soils, higher organic soil content, and higher floodwater retention. Instead of externalizing the costs of poor land management practices, this approach could help farmers internalize the benefits of excellent land stewardship. These modest investments will yield innumerable savings over time and, more importantly, reduce loss of life and property and mitigate the impacts of floods and droughts.

NCAT Contact: Steve Thompson, Executive Director - Stevet@ncat.org

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Footnotes:

1/ USDA NRCS video demonstration: https://www.youtube.com/watch?v=IqB4z7lGzsg

2/ Lara Bryant, Natural Resources Defense Council, 2015, Organic Matter Can Improve Your Soils Water Holding Capacity; https://www.nrdc.org/experts/lara-bryant/organic-matter-can-improve-your-soils-water-holding-capacity

3/ Kaye, J. P., & Quemada, M. (2017). Using cover crops to mitigate and adapt to climate change. A review. Agron. Sustain. Dev, 37, 4. https://doi.org/10.1007/s13593-016-0410-x

4/ Schnoor, J. L. (2014). Water Quality and its Sustainability. In Comprehensive Water Quality and Purification (Vol. 4, pp. 1-40). Elsevier Inc. https://doi.org/10.1016/B978-0-12-382182-9.00057-8

5/ Rowntree, J. E. et al. (2020). Ecosystem Impacts and Productive Capacity of a Multi-Species Pastured Livestock System. Frontiers in Sustainable Food Systems, 4, 232. https://doi.org/10.3389/fsufs.2020.544984

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

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