Nature Conservancy Issues Public Comment on FEMA Notice

WASHINGTON, July 27 -- Sarah Murdock, director of the U.S. climate resilience and water policy at the Nature Conservancy, Arlington, Virginia, has issued a public comment on the Federal Emergency Management Agency's notice entitled "Technical Mapping Advisory Council; Meeting". The comment was posted on July 24, 2020:

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Thank you for the opportunity to comment prior to the Technical Mapping Advisory Council's (TMAC) meeting on July 27, 2020. The Nature Conservancy (TNC) believes there three critical issues that the Council needs to incorporate into a proposed vision statement for the flood mapping program and include in the 2020 TMAC report and 2021 work plan: future conditions mapping, integrating flood risk and natural floodplain functions, and Atlas 14 updates. TMAC has addressed some of these issues in the past but FEMA has not made meaningful changes. TNC urges TMAC to ensure FEMA's consideration of these issues. Should you have any questions about these recommendations, please reach out to Sarah Murdock ([email protected]), TNC Director of US Climate Resilience and Water Policy.

TNC is a global conservation organization dedicated to conserving the lands and waters on which all life depends. Guided by science, we create innovative, on-the-ground solutions to the world's toughest challenges so that nature and people can thrive together. We are tackling climate change, conserving lands, waters and oceans at unprecedented scale, providing food and water sustainably and helping make cities more sustainable.

Working in all 50 states and 72 countries, we use a collaborative approach that engages local communities, governments, the private sector and other partners, including farmers, ranchers and other landowners.

TNC engages and invests in conservation and restoration projects in varied ecosystems throughout the United States that result in flood risk reduction. We have drawn on our extensive project experience and expertise in carrying out this work to offer the following comments on these three issues. Incorporating additional data sets and information into FEMA map products will greatly enhance the quality of community vulnerability studies.

NGOs like TNC and private companies create decision support tools to assist and supplement the vulnerability assessment process. TNC has developed several such tools such as our coastalresilience.org and Floodplain Prioritization Tool. Adding additional layers of data to FEMAs flood maps will greatly improve communities' ability to develop robust vulnerability assessments and associated strategies aimed at ultimately reducing flood disaster risk.

Future conditions mapping

In the 2012 National Flood Insurance Policy (NFIP) reform legislation, Congress directed FEMA to incorporate future conditions in development and display of flood maps. In the 8 years since that congressional directive, the NFIP has not incorporated future conditions into its maps. Because of this, every flood map produced by the NFIP is outdated by the time it is issued. As a result, communities throughout the nation continue to develop in areas that are not mapped in the NFIP-marked Special Flood Hazard Area (SFHA) without knowing that the SFHA will soon shift due to climate change. Developers are investing in these properties based on inaccurate risk information. Property owners within or outside of the NFIP-marked SFHA also have inaccurate risk information which means they purchase inaccurately rated flood insurance or don't purchase flood insurance at all. Both issues greatly impact the solvency of NFIP.

Recommendation:

TMAC should recommend FEMA move to incorporate future conditions in all flood maps. This may require added layers in the current flood level digital models, which are used for flood insurance rating, as well as added layers in the future expected flood level models.

Integrating flood risk and natural floodplain functions

Over the past fifteen years, the U.S. has experienced increasingly intense precipitation events that have resulted in property and infrastructure destruction and loss of life. In response, federal, state, and local stakeholders have increasingly employed natural floodplain and wetland restoration to reduce flood risk and improve overall watershed health. The NFIP's Community Rating System (CRS) promotes comprehensive floodplain management planning and analysis of natural floodplain function and habitat protection. However, FEMA's Risk Mapping, Assessment and Planning (RiskMAP) program generally lacks incorporation of natural systems and significant habitat data. This program primarily focuses on elevation, hydrology, infrastructure, hydraulics, and land use data. Because of this, the RiskMAP program does not help inform and facilitate consideration of nature-based solutions, an important and powerful tool in flood risk mitigation and endangered species protection.

If RiskMap products incorporated geospatial data that illustrates floodplain functions (including wetlands, coastlines, streams and rivers) as dynamic, hydrologically connected components of a larger watershed, this would result in better local strategies including restoration and land conservation prioritization. This would reduce flood risk while increasing co-benefits such as recreation, clean drinking water, and avoided damage costs. Examples of existing models that capture aspects of floodplain function include the U.S. Army Corps of Engineers' hydrogeomorphic (https://www.erdc.usace.army.mil/Media/Fact-Sheets/Fact-Sheet-Article-View/Article/476738/hydrogeomorphic-approach/) approach to mapping for compensatory mitigation projects. This approach ensures any impacted wetland or stream functions are replaced by the mitigation project. Similarly, the U.S. Forest Service recently completed its National Riparian Inventory Base map (https://storymaps.arcgis.com/stories/8cd69adaaaf541c78f8d867f0ec6b6ef) which recognizes the dynamic and transitional nature of riparian areas by accounting for hydrologic, geomorphic and vegetation data as inputs.

Recommendation

TMAC should recommend that FEMA incorporate natural floodplain function and habitat analysis into its RiskMAP program. This would increase development and implementation of local natural and nature-based strategies.

Atlas 14 updates

Precipitation data for the 1% rainfall event, updated LiDAR data, and appropriate hydraulic models are critical to creating accurate flood maps. The precipitation data in flood maps often comes from Atlas 14 publications, which are precipitation frequency atlases produced by National Oceanic and Atmospheric Administration (NOAA). However, a number of the Atlas publications (produced by states or regions) are far out of date, with some being decades old. This means flood maps consistently underestimate risk and do not accurately show which properties need to buy flood insurance.

One reason for the out of date Atlas 14 volumes is a lack of guaranteed federal funding. Funding for updates to Atlas 14 needs to be a federal data responsibility yet NOAA currently relies on voluntary contributions from states and other agencies to fund updates to the volumes.

Recommendation:

TMAC should recommend NOAA receive annual federal funding to update every Atlas 14 publication every 5 years.

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The notice can be viewed at: https://beta.regulations.gov/document/FEMA-2014-0022-0044

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