National Wildlife Federation Issues Public Comment on FEMA Notice

WASHINGTON, Oct. 23 -- Jessie Ritter, senior director for water resources and coastal policy, and Brittney Parker, resilient coasts and floodplains policy specialist, at the National Wildlife Federation have 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 Oct. 14, 2021, and posted on Oct. 18, 2021:

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On behalf of National Wildlife Federation (NWF), the nation's largest conservation organization with more than six million members and supporters nationally, we would like to thank the Federal Emergency Management Agency (FEMA) for taking steps to effectively work to transform the Community Rating System (CRS) under the National Flood Insurance Program (NFIP). NWF represents a national network of like-minded state and territorial groups, seeking balanced, common-sense solutions that help people and wildlife thrive.

The goal of the CRS Program is to promote responsible community level floodplain management and flood risk mitigation in order to reduce the associated flood risk to NFIP insured properties. The current CRS activities and associated points account for a wide variety of actions which go above and beyond the minimum floodplain management requirements. With an extremely complex manual, and a large number of activities with complex dependencies and interrelations, a wholistic evaluation of the program is needed to determine if current CRS activities are driving measurable community flood risk reduction, and if the associated points accurately corelate point allocations with effectiveness of risk reduction. Additionally, activities which result in the most measurable flood risk reduction should be expanded to encourage communities to take steps toward achieving those outcomes. Further, the minimum standards of the program should be reviewed and updated to reflect modern best practices for floodplain management and flood risk reduction, including comprehensive incorporation of climate change considerations and forward-looking climate adaptation strategies.

Previous updates to the CRS Manual have incorporated climate change considerations across some activities. However, a more robust and thorough integration of modern climate science and climate adaptation management considerations is needed holistically across the entire program. This includes but is not limited to considering and planning for the increased frequency and intensity of rain events and other extreme weather events (like those that caused catastrophic flooding in Tennessee and related to remnants of Hurricane Ida in New York and New Jersey) and sea-level rise and the impact of coastal inundation and increased erosion. These integrated climate considerations will reduce future flood risk for communities and encourage smart adaptation and planning.

Preservation and restoration of natural systems which reduce erosion and absorb floodwaters, like healthy floodplains and coastal wetlands, are key best practices in floodplain management. NWF is highly supportive of the current emphasis of the CRS program on preservation of open space as one of the most highly valued activities. Importantly, this existing activity also awards points for fully restored floodplains within preserved open space, with an emphasis on the restoration of natural floodplain functions and protection of habitat for endangered species. Under this activity naturally preserved waterways and shorelines also receive credit; however, based on our interpretation, other nature-based solutions (known as natural or green infrastructure) which have valuable flood risk reduction functions do not receive points through the CRS program. For example, green infrastructure like living roofs, permeable pavers, and bioswales can be key small-scale adaptive tools to reduce flood risk in urban centers, but are not currently credited under the program. Utilization of living shoreline restorations along coasts and rivers presents a valuable flood and erosion risk reduction tool which should be encouraged and valued under the program. Additionally, techniques like oyster reef construction and mangrove restoration can reduce coastal erosion, which is a key statutory requirement of the CRS program. Overall, additional functions of natural defenses that leverage ecosystem capabilities to absorb flood waters, stabilize shorelines, and reduce erosion, should be considered and valued under the CRS system, in addition to credits already provided for preservation of systems in their natural state and for open space restoration. In many areas including urban centers, nature-based projects can be used to reduce flood risk, while also providing valuable community services like recreation opportunities and extreme heat reduction.

Additionally, active CRS community participation is somewhat limited, with only about 6.5% of communities with NFIP policies currently enrolled in CRS. Management of the program can be burdensome to smaller municipalities that may already be capacity-limited due to budget and staff limitations. Providing support and incentives for new communities to join into the CRS Program - particularly small, under-resourced, and/or low-income communities - is a much-needed step to expand participation and ensure all interested communities have access to CRS program benefits. The CRS Program submission process itself could be made more user-friendly though a digital portal or profile containing information to help managers understand the complex point system. This portal could create town profiles, saving past information to streamline the required annual activity updates. This may also make it clearer to communities what activities can still be maximized and information is needed to advance through the program.

We also note that there is an inherent misalignment between the level where decisions about participation in the CRS Program are made and where the actual benefits of participation accrue. Individual policy holders benefit from the reduction in their NFIP policy rates; however, it is the municipality, and not the individual policy-holder, that bears the responsibility for administering the CRS program. In many communities, individual policy-holders often lack knowledge about the program and its potential benefits - a barrier for expansion of participation. Providing some sort of incentive for municipalities to begin or continue participating would be significant in attracting new communities and retaining communities in the program. A potential attractive community-level incentive could be additional technical assistance and capability and capacity building resources to communities participating in the CRS. This support could dually provide technical assistance to help launch and manage CRS programs, while also contributing to wider FEMA mitigation application and program management. This benefit could be aimed at under-resourced, low-income, or low capacity communities (similar to BRIC's Direct Technical Assistance category) as a multi-year, non-financial direct technical support to encourage new communities to begin participation in the CRS program.

NWF would again like to thank FEMA for the opportunity to provide input on ways to improve the CRS Program. We stand ready to assist should any further questions arise.

Sincerely,

Jessie Ritter, Senior Director, Water Resources and Coastal Policy, National Wildlife Federation

Brittney Parker, Resilient Coasts and Floodplains Policy Specialist, National Wildlife Federation

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

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