Santa Clara, Calif., Issues Public Comment on FEMA Notice

WASHINGTON, Oct. 28 -- The city of Santa Clara, 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 Oct. 25, 2021:

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1. Element 452 - Stormwater Management Regulation (SMR)

The current SMR is tailored for developing communities that still have undeveloped land. The current SMR language is very difficult for a fully developed city to achieve. For a fully developed and older community, such as our city, there is little to no undeveloped land and most are infill developments on existing developed land. If there is sub-category under SMR for fully developed communities, that would provide entry point for cities like ours.

2. Element 542 - Storage Basins Maintenance (SBM)

Would FEMA consider making technical reviewer more accessible to communities seeking credits? We would like recommendations from technical reviewers or subject matter exports to help our city improve. We previously submitted requests to ISO for feedback from the technical reviewer on element SBM, and did not receive any response.

3. Activity 610 - Flood Warning and Response

We would like to improve our flood warning and response plan. Would FEMA be open to provide model flood warning and response plans for communities to use? The effort required to create a flood warning and response plan, that qualifies for Activity 610 credits, from scratch has been a barrier to our city.

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

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