Scottsdale, Ariz., Drainage & Flood Control Program Manager Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 16 -- C. Ashley Couch, drainage and flood control program manager at City of Scottsdale, Arizona, 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. 15, 2021:

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May I please offer the following comments?

1. Make documentation of creditable activities simpler and less time-consuming!

2. Restore credit for volumetric-based stormwater storage basins, which was withdrawn in the 2021 addendum to the 2017 CRS Coordinator's Manual. Currently, only stormwater storage basins based on pre vs. post hydrology are fully creditable, even though this requires far more engineering, and even though everywhere in Scottsdale, volumetric-based basins provide more flood attenuation than pre vs. post basins (The Flood Control District of Maricopa County and I have tested this and confirmed it to be true). Every community in the Valley that I am aware of has volumetric-based design like we do, so no one in the Valley receives full credit for this anymore, and it's worth 225 points, plus it impacts other creditable elements for which it is difficult to quantify the additional loss of points beyond the initial 225.

3. Change the scoring mechanism for Activity 610--Flood Warning and Response. Currently, if you get zero credit for any of the required first four elements of a Flood Warning and Response Plan, you get zero points, period. This was first implemented in the 2017 CRS Coordinator's Manual.

While the goal of the CRS Task Force was to stress the importance of having a comprehensive plan, the result has been the opposite--that communities do not bother doing any of these first four elements if they don't plan to or can't do all four, because they will not get any credit for it. One of these first four required elements has a requirement that there be three inundation maps and specific plans for each level of inundation. In Scottsdale, all flooding is flash flooding, so this step is completely unfeasible, as it is for most of Arizona and the arid southwest.

Consequently, we no longer receive any credit for Activity 610. In fact, no Arizona community receives credit for CRS Activity 610 anymore (at least as of a year or so ago). When the CRS Task Force was drafting the language for the 2017 CRS Coordinator's Manual, as part of an AFMA initiative, I helped draft, along with a couple of other AFMA members, a letter to FEMA, ISO, and the Task Force strongly discouraging these parties from implementing their proposed approach, but they did not heed our input.

In this letter, I proposed an alternative approach, that I am convinced would work far better--to provide credit for each of the seven creditable elements of a plan, and to provide bonus points for communities who are able to implement a comprehensive plan. Unfortunately, they rejected my proposal, even after I spoke with several CRS Task Force members in person about it.

Best regards,

C. Ashley Couch, P.E., CFM

Drainage and Flood Control Program Manager

Floodplain Administrator

CRS Coordinator

City of Scottsdale, Arizona

480-312-4317

[email protected]

Stormwater Management Department

7447 E Indian School Road, Suite 125

Scottsdale, AZ 85251

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

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