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We recognize the CRS program is intended to motivate local governments to reduce flood risk exposure by offering premium credits on flood insurance policies. Premium discounts offered through CRS are one of the only affordability measures in the National Flood Insurance Program (NFIP), making it an important lever to ease increasing flood insurance costs. Affordability is a special concern in
Given the potential value of CRS to our residents, the City continues to research and evaluate entry into the program. Unfortunately, the current iteration of CRS contains several limitations that impair our ability to join. We note that
Our comments focus on
Our specific recommendations are as follows:
1. Allow for greater flexibility to meet conditions of highly variable communities across the country. Floods are the most common and costly natural disaster, impacting rural, suburban, and urban settings nationwide. The diversity of built environments, histories, and types of flood risks means successful mitigation strategies must reflect the context within which they are implemented. Local governments must adopt context specific flood mitigation strategies that meet the needs of residents.
Despite this, the current iteration of CRS offers minimal credit for discretionary floodplain management activities and regulations. Instead we recommend the CRS program inspire creative approaches and leverage unforeseen opportunities for floodplain management activities that reflect the diversity of local governments, regulations, and contexts across participating NFIP communities.
For example, CRS currently prioritizes removing and reducing flood risk through property acquisition, building elevation, and open space preservation./3
As a result, these mitigation activities generate the largest number of CRS points. However, these mitigations are simply unachievable on a large scale in older, denser cities like
2. Revise CRS scoring to resolve bias against older, denser cities. In its current form, CRS scoring often favors smaller communities. For example, a CRS community that acquires 100 of 1,000 structures in the floodplain receives substantially less credit than one that acquires 10 of 15 structures in the floodplain. Consider the magnitude of
Further CRS challenges exist for older, denser cities. CRS participation hinges on a single Community Assistance Visit (CAV) regardless of the geographic size of the NFIP community and the magnitude of properties in the community's floodplain.
Communities that already participate in the CRS program face similar limitations when seeking advancement within the program. Prerequisites for advancement to higher classifications are uniform regardless of an NFIP community's size, built environment, and flood risks. For example, a Class 4 rating can only be achieved once an NFIP community demonstrates specific point thresholds in certain CRS activities, as well as a BCEGS rating of 4/4. Nationwide, only 20 NFIP communities have achieved a rating of Class 4 or higher, suggesting the ability for advancement is severely limited. Therefore, the City recommends the CRS program incorporate flexibility into the requirements to reflect the diversity of NFIP communities across the nation.
Furthermore, Elevation Certificates (EC) currently play a significant role in the CRS program but will be optional for flood insurance purposes under
3. Improve transparency of the CRS program, including enforcement oversight. Prospective CRS communities often undertake substantial regulatory and enforcement action ahead of a CAV to ensure the community meets minimum NFIP standards. Once a community is in CRS, it is subject greater scrutiny and it is politically incentivized to maintain or increase its CRS rating.
Available enforcement tools for NFIP communities to address non-compliance with NFIP standards are often limited, but
Additionally, reports on CRSResources.org which lists credits received by individual states and communities by category are out of date and only the classes of CRS participating communities are publicly accessible. Current and aspiring CRS communities should have up-to-date access to sub-activity scores and the impact adjustments of other communities to better understand the suite of tools available through CRS and their practicality. By reporting detailed information about points and activities that participating CRS communities are receiving, there will be greater transparency into the program. This may also lead to greater collaboration and cooperation between communities.
4. Reduce the administrative burdens of CRS enrollment and participation and increase
Additionally, municipalities have varying procedures and requirements for issuing permits and conducting inspections to certify a property meets flood-resistant construction standards. These processes often pre-date NFIP participation and changes to comply with CRS rules could result in an overhaul of the entire permitting system. For example,
Finally, NFIP communities entering CRS are required to correct inaccurate ECs. This can be impractical, especially when construction has long since been completed and when review and correction may require considerable staffing. To provide communities with assistance, the CRS program should provide a more "hands-on" approach, including facilitating a review of ECs and coordinating more closely with communities to correct the forms. This closer coordination could benefit design professionals on both side of the permitting counter by adding extra oversight and learning opportunities.
Thank you for this opportunity to comment on the Community Rating System.
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3/ Activities 520 and 530 offer points for flood protection and mitigation activities, which include elevation and acquisition of a property; Activity 420 offers points for open space preservation.
4/ Based on
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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0021-0001
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