Southwest Florida CRS Users Group Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 24 -- Billie Jacoby, community rating system coordinator at Lee County Southwest Florida, Fort Myers, has issued a public comment on behalf of the Southwest Florida CRS Users Group 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. 21, 2021, and posted on Sept. 22, 2021:

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Please accept these comments on behalf of the Southwest Florida CRS Users Group:

Activity 310 (Access to the Elevation Certificate Validation Tool utilized by ISO) With the amount of staff hours that must be invested in making sure ECs are correct, it would seem just as logical to allow communities to utilize the validation tool/software. This would be another "tool in the toolbox" (not intended to replace the current protocols/staff review process).

Mitigation Grant Credit

* Proposal to create an activity that gives credit to communities for putting projects on local or regional mitigation planning lists and pursuing mitigation grants (HMGP, BRIC, FMA, CDBG, state grants).

* An immediate thought would be a distinction between grants applied for versus grants awarded, and maybe even grants completed

* Having a credit scale based on the above-referenced phases that exist at time of verification/re-cert

Activity 420/Open Space (State or Local owned lands located within Federally owned/maintained preserve areas):

* This is a unique scenario which Collier County experiences. Example: The County and State own lands within the Big Cypress National Preserve which is a federally owned preserve. At this time, CRS guidelines dictate communities may not receive Open Space credit for federally owned/maintained lands located in the SFHA. While a unique situation, we believe the County should receive credits for these lands with adequate documentation verifying the ownership.

* Proposal to receive credit for federally owned open space based on the support services to provide public access maintenance, traffic control or any other types of agreements of understanding with Federal agencies for that property. Example: Ding Darling.

Activity 420/Open Space (Golf Course Eligibility for Open Space Credit):

* Currently, in order to receive Open Space credit for golf courses in the SFHA a community must provide documentation stating that the subject golf course will be remain as Open Space in perpetuity. Per the CRS Manual, this is achieved by producing a letter from the Golf Course Manager or by similar language being located in a PUD/plat note etc. We would like to explore the possibility of keeping a historical file of aerial photography to provide as evidence that the golf course inventory has not been altered through new development or redevelopment in lieu of producing the required documentation at this time.

Emergency Preparedness

States like Florida that have very specific Emergency Preparedness requirements which include a lot of 610 flood items, due to hurricane storm surge, there should be automatic credit for such things as; Special Needs data bases, Flood mitigation (LMS) Flood Plans (CEMP), Flood Notification Systems (FL provides this for free to each County), etc. If you are compliant with the State of FL for their hurricane preparedness requirements, you shouldn't have to prove those items (like the old State Universal Credit).

ISO Reviews

Provide more consistency between reviews and a formal "close out" letter explaining why credit was not received for a particular element even though it was submitted.

Respectfully submitted,

Southwest Florida CRS Users Group

(Primary contact: Billie Jacoby, CFM)

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

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