Sacramento, Calif., Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 23 -- The city of Sacramento, 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 posted on Sept. 21, 2021:

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CRS Program Input City of Sacramento

* Activity 310 Construction Certs- Provide examples of approved comprehensive maintenance plans that are required to be included with the Floodproofing Certificates. What the comprehensive maintenance plans should look like for Floodproofing Certificates.

* Overall: Discrepancy in scoring and points from previous years visits. Less points received than the previous years' cycle although the program has remained the same and the CRS manual did not change the requirements. Would be helpful to have a more specific scoring rubric provided to communities when the cycle is complete. More explanation about partial credit and how it was determined. Would help us gauge what activities are worth doing.

* Substantial improvement calculation- More explanation on how substantial improvement should be calculated. 1 year rolling back from permit application? Permit activity? There are many different stages of permits which one do we base our year off of?

* Costs of studies for Levee certifications - Is there FEMA funding to offset some of these costs? Grants? Can we tie in some of our projects (interior drainage studies master plans etc.) and how these requirements are cost prohibitive to communities. And how do we pay for improvements if you share the levees with other communities?

* Input on the Watershed Master Plan (452.b). Do you have any recommendations on how we could not have these standalone items and integrate these items elsewhere in our flood programs? Is the WMP a useful plan?

* Activity 630 Dams- We only receive credit for 632.a State Dam Safety Program. We cannot get sensitive information from the dam owners due to security issues or willingness/able to share some materials with the local agencies, thereby no able to apply for those other dam credits.

* There's a disproportion on the number of points awarded in comparison to the level of effort/work involved in providing the documentation.

* The entire CRS scoring methodology needs to be re-visited.

* Equity needs to be considered when providing credited points. Are older, larger and more complex drainage systems being considered when awarding points?

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

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