Southwestern Illinois Flood Prevention District Council Issues Public Comment on FEMA Notice

WASHINGTON, Jan. 29 -- Charles M. Etwert, chief supervisor of construction and works at the Southwestern Illinois Flood Prevention District Council, Collinsville, has issued a public comment on the Federal Emergency Management Agency notice entitled "Request for Information on the National Flood Insurance Program's Floodplain Management Standards for Land Management and Use, and an Assessment of the Program's Impact on Threatened and Endangered Species and Their Habitats". The comment was written on Jan. 25, 2022, and posted on Jan. 26, 2022:

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As the Southwestern Illinois Flood Prevention District Council (FPD Council) works toward maintaining the accreditation of the Metro-East St. Louis levees in the National Flood Insurance Program (NFIP) we appreciate the opportunity to offer this response to the Federal Emergency Management Agency (FEMA) October 12, 2021, Federal Register notice requesting information on changes to the minimum floodplain management (FPM) requirements.

The FPD Council was formed in July 2009 by Madison, Monroe, and St. Clair counties in direct response to FEMA's announcement of its intention to de-accredit the 74-mile system of levees protecting the St. Louis Metro East region. FEMA's decision would have designated substantial portions of the American Bottom area of Southwestern Illinois as a Special Flood Hazard Area (SFHA) on updated flood maps and caused devastating economic impact. Recognizing the urgency of this situation, regional leaders successfully sought authorization from the Illinois General Assembly to impose a 1/4 percent sales tax to pay for any necessary improvements to the levees and created independent Flood Prevention Districts (FPDs) within each county with the authority to collect the tax.

The FPD Council was formed by the three county FPDs as a joint venture to oversee the improvement of the Metro East levee systems so they can continue to protect the lives, property, and the economic vitality of the St. Louis Metro East region. We worked aggressively over nearly a decade, through two record flood events, to complete $75 million in construction, and in 2018 completed the projects needed to certify that our levee systems meet the FEMA NFIP standards to be accredited as providing 100-year level of protection on the FEMA flood maps.

The work to meet the NFIP standards for 100-year flood protection was done ensure the American Bottom, an area of 174 square miles in Southwestern Illinois that is home to 156,000 people, 4,000 businesses and 56,000 jobs in 25 communities in Madison, St. Clair, and Monroe counties, would not be declared Special Flood Hazard Area (SFHA) by FEMA. Being identified and regulated as an SFHA would have dire consequences for our region's overall economy, as well as its many individual businesses and homeowners. Not only would the imposition of the floodplain management requirements be challenging for the businesses located in the levee protected areas there would also be required mandatory purchase of flood insurance for any home or business with a federally backed loan at exorbitant rates in many instances.

Having now met the applicable requirements for recognition of 100-year level of protection we are disturbed to see in the subject notice that FEMA may be contemplating changes to how the SFHA will be defined or regulated. Moreover, we can see no fair means by which to increase the extent of the SFHA boundary beyond that of the current 100-year event, in part because the reliability of determining the flood boundary for less likely (i.e., 500-year) events is largely inconsistent across the nation. We are also concerned that increased regulation for areas "adjacent" to the SFHA will not appropriately acknowledge the benefits of reliable flood protection infrastructure.

Our communities are presently seeking to understand the impact of FEMA's new Risk Rating 2.0 methodology with a new means for both determining and pricing flood risk. We know that in leveed areas this is based on several assumptions and other information not made available to the public or even the non-federal owners of levee systems. We urge FEMA to share that information so that owners of levee infrastructure and the communities they protect can understand how flood risk is being calculated in leveed areas. It is important to know how the risk reduction benefit provided by reliable levees will impact a property's flood risk determination and the pricing of its insurance under the NFIP. Purportedly the flood risk determinations made using FEMA's new methodology are an improvement over the information shown on the current versions of FEMA's flood maps. Hence, we urge FEMA only consider changes to the NFIP floodplain management requirements after Risk Rating 2.0 has been fully established (with risk in leveed areas being appropriately determined) and the results of this new methodology fully understood (including how this data source will be incorporated into the next iteration of flood maps).

We hope you respect that our region has worked hard to emerge from a period of uncertainty brought on when FEMA sought to map our levee protected communities as SFHA based on the U.S. Army Corps of Engineers having "reduced confidence" that the 74-mile levee system could protect against a 100-year flood. The results of what we've accomplished over the past 12 years must not be invalidated. We cannot afford to reenter a period of economic uncertainty that would arise from potential changes to floodplain management regulations that we cannot understand the implications of without first having an informed understanding of FEMA's new flood risk determinations for leveed areas under Risk Rating 2.0 and how that may be mapped.

Thank you for your consideration of these comments. Should you have questions or additional information be needed, please contact Karin Jacoby at 816-983-8304.

Sincerely,

Mr. Charles M. Etwert

Chief Supervisor of Construction and the Works

Southwestern Illinois Flood Prevention District Council

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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0024-0001

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