Riverside County Flood Control & Water Conservation District Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 24 -- Hilal Elhaddad, senior civil engineer for floodplain management at the Riverside County Flood Control and Water Conservation District, California, 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 written on Sept. 22, 2021, and posted on Sept. 23, 2021:

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The Riverside County Flood Control and Water Conservation District (District) is the regional flood management authority for the western part of Riverside County. The District manages the westerly 2, 700 sq. mi. of the County, which extends easterly through the cities of Palm Springs, Cathedra l City, and Desert Hot Springs. The District is tasked with the construction, operation, and maintenance of drainage facilities within the western portion of Riverside County. In addition, the District manages and regulates developments located within flood hazard areas to protect life and property. The District recently secured a Community Rating System (CRS) Level 6 which takes effect April I, 2022.

In response to your Request for Information (RFl) dated August 23, 202 1 on the National Flood Insurance Program's CRS, the District is offering the following comments:

1. Impact Adjustment Factor. Certain CRS Activities such as 410, 420, 520, and 540 require impact adjustment calculations, which typically favor smaller communities rather than larger communities. Under the current program, the final point calculation is not a function of the effort toward helping the community, but a percentage of Special Flood Hazard Area (SFHA) affected by the effort versus the total SFHA. As a result, large communities will always receive reduced points over a smaller community for the same level of effort; as such, large communities such as Riverside County are not given appropriate credit due to the current method. Large communities are not rewarded and may even become disincentivized because the effort and staffing commitment are not commensurate to the point value given. Therefore, we recommend that the methodology and formulas be revised to accommodate an accurate point value for both large and small communities; the new manual should consider and implement a fair and reasonable point distribution calculation for both small and large communities.

2. Activities that benefit another CRS community. The District as a CRS community technically only includes the unincorporated areas of western Riverside County. However, we have 28 cities within our County that also benefit from our flood protection efforts. The District constructs drainage facilities and processes many LOMRs that ultimately remove entire flood hazard areas and structures from the floodplain; many of our LOMRs are either entirely or partially in one of our cities. However, the District cannot claim credit due to the fact that the drainage facilities and the flood hazard areas removed are within the Cities' jurisdiction and not within the unincorporated County. As a result, the CRS cred it is awarded to a City instead of the County. The new manual should develop a methodology that will award credit for conducting CRS activities that benefit another community.

CRS Documentation. Documentation requirements for certain Activities such as 4 10, 45 0, 5 10, and 630 are too cumbersome, overly specific, and stringent relative to the available point values. For instance, Activity 450 requires the community to adopt and implement a watershed plan to require new development to control the 25-year event onsite. Attempting to receive credit for such activity might require documentation such as ordinance update and hydrology and hydraulic manual changes in order to receive points. Additionally, Activity 630 requires excessive documentation about the levee system maintenance relative to the associated point value; documentation includes maintenance activities performed, frequency, person responsible, annual tests of all closures, emergency action plan, and many others. In many cases, failing to meet a certain criterion may disqualify or limit the points for this activity. For large communities such as ours, due to the large number of facilities and the scope, magnitude, and frequency of our continuous maintenance efforts required to ensure capacity, the larger communities need a better process that is suited for tracking hundreds of facilities or an alternate or more flexible method for showing FEMA that we are meeting or exceeding the CRS requirements. Communities should be able to receive partial credit based on submitting adequate documentation to support their activities. In many cases, it would be more efficient to implement regulation in a small city, but this same process does not work well in a larger community; again, the effort should be commensurate to the point value. The new manual should provide reasonable methodologies and requirements for both small and large communities.

The District would like to thank FEMA for the opportunity to provide feedback/comments, and we look forward to making this program even better for the communities we serve. Should you have any questions, please direct them to:

Hilal Elhaddad, M.S., P.E., CFM

1995 Market Street

Riverside, CA 92501

951.955.1265

haelhadd@rivco.org

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

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