Sacramento County, Calif., Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 28 -- The County 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. 27, 2021:

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610 DCF 1 credit is very hard to attain. Names and phone numbers of all public and private critical facilities updated annually for a Federal (unmapped) dam inundation area is unreasonable.

340 DFH Providing documentation that real estate agents are disclosing the hazard to a buyer is not appropriate. The agent is dealing with a buyer, and as a local government agency, we have no right to ask for this documentation.

We are not involved in obtaining the paperwork that happens between agent and buyer. The agent does not have to answer to the local government agency (they would feel like we are auditing them). The agent also typically uses a third party for determinations.

Cycling between things that are due every 5 years BUT are due if it is a 3-year cycle visit makes things very confusing. We tried to lump things onto the same cycle, only to find out there are different timelines because of a cycle visit. This would really matter for community transitioning classes.

As a larger community, submitting items is very time consuming. Consider staggering activity due dates (ECs are annual no so consider that too for timelines). Larger communities have more items to pull together (especially if they are higher class).

Consider allowing for more flexibility for the way we demonstrate compliance. There seems to be an intent in the Activities and as long as we are meeting that intent, seems that is the reason also for the visit. Black and white on paper doesn't demonstrate intent very well.

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

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