Sugar Land, Texas Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 24 -- The city of Sugar Land, Texas, 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. 23, 2021:

* * *

The below non-exhaustive list of questions is meant to assist members of the public in the formulation of comments and is not intended to restrict the issues that commenters may address:

1. What are the strengths of the current CRS program? What components of the program are currently working well and why?

a. Program encourages communities to implement higher standards that will create safer, flood protected and more resilient communities.

b. Encourage safer development in the floodplain and a better use of the resources.

c. Provides a financial incentive for communities to participate in the CRS program.

2. What are the challenges with the current CRS program that need to be addressed and why? How can the CRS program be modified, expanded, or streamlined to better address or resolve these challenges?

a. The CRS program should provide a better and easier way to submit and store the information required to participate in the program.

b. FEMA should create a web base platform to storage all the required information.

c. The program takes a lot of resources (financial and man hours) to comply.

d. The financial incentives to residents do not correspond to the effort implemented by the communities to participate in the CRS program.

3. While the CRS program is technically available to all compliant NFIP communities, is access to the CRS program equitable for all communities? If not, what changes to the CRS program could make it more equitable for all communities? How could the CRS program provide better outreach to disadvantaged communities to encourage participation? How could the CRS program provide better outreach to households in disadvantaged communities to encourage participation in the NFIP?

a. CRS could offer a small (1-2%) discount for joining the program (Class 10)

b. Offer direct assistance from ISO to smaller communities to assist in building the required ordinances/programs for the CRS program.

c. Additional percent discount should be offered to communities that participate in the program for several years.

4. How could the CRS program better promote and/or incentivize improved reduction of future conditions and risks such as climate change, sea-level rise, urban flooding, and future development?

a. Educate developers and citizens on the risk of building in or near the floodplain and flooding sources.

b. Require disclaiming the flood risk areas during the sale of any property in the floodplain.

5. How could the CRS program better address the mitigation of repetitive loss/severe repetitive loss [14] properties and how could FEMA further leverage the CRS program to achieve mitigation of repetitive loss/severe repetitive loss properties?

a. Provide financial assistance to CRS communities to buy out homes prior to the NFIP classification of RL/SRL, including the loss of revenue to the taxing authorities.

b. Lower the threshold required for mitigation of repetitive lows properties.

6. How can the CRS program be modified, expanded, or streamlined to best incentivize participation by communities and flood insurance policyholders to become more resilient and lower their vulnerability to flood risk?

a. Provide better financial incentives for people that buy food insurance within CRS communities, effective from the day they purchase flood insurance regarding of the level of risk

b. Provide incentives to people that maintain their insurance year after year and reduce premiums for people that have no claims.

7. How can the CRS program better incentivize floodplain management, risk management, and/or risk reduction efforts for communities through CRS discounts, grants, trainings, technical assistance or other means? Which efforts are most critical for the CRS program to support?

a. Incentivizing the decreasing in class or maintaining the same class rating by providing additional discounts for communities that do so (additional percentage off if lowering class, additional few percent off for maintaining class rating at each cycle, compounding over time)

8. What existing sources of data can FEMA leverage to better assist communities to assess, communicate, and drive the reduction of current and future flood risk? Can FEMA leverage new technologies to modify or streamline the CRS program? If so, what are they and how can FEMA use new technologies to achieve the statutory objectives of the program?

a. Update the DFIRMs more often in urban areas and areas with large percent development to assist in flood plain changes/management.

b. Provide access to the data that FEMA has collected that the communities do not have access to.

c. Create a central database to collect and share all flood data available per community, county, etc.

9. The CRS program provides credits for flood risk reduction activities. Are there flood risk reduction activities that are not currently given credit within the CRS program that should be? If so, what are they and why? Are there flood risk reduction activities that are currently given excessive credit within the CRS program than they should be given? If so, what are they and why? Should the CRS program provide a list of optional risk reduction activities for communities to choose from or a list of required risk reduction activities, and why?

a. Some activities like the mapping activities have a large number of points, and require a large amount of technology but not much effort after the maps are established. Activities like outreach have too many low caps on points (5 times for a total of 10 points on the same outreach program) or capping the number of points that a community receives for CFMs

10. What successful approaches have been taken by State, local, Tribal, and Territorial governments that the CRS program could leverage to better support community participation in the CRS program? In what ways could the CRS program better support States, Tribes, Territories and Regions, and flood control and water management districts to improve community participation in the program? What innovative changes could the CRS program make to be simpler for communities to join and maintain participation?

a. Texas has created flood planning regions for the entire state based on Watershed for flood planning.

b. It will be better to have a regional CRS program based on communities that share the same watershed(s), and work together to reduce flood risk at their regional level.

11. How could the CRS program provide better outreach to disadvantaged communities to encourage participation? How could the CRS program provide better outreach to households in disadvantaged communities to encourage participation in the NFIP?

a. Need to create public awareness with commercials, internet ads, etc.

12. In what ways could the CRS program facilitate collaboration across jurisdictional boundaries to support a community's ability to reduce flood risk? How could the CRS program be modified, expanded, or streamlined to allow for multi-jurisdictional collaboration efforts to receive credit under the CRS program?

a. Incentivize communities to plan together as a watershed by providing points for doing so, rather than planning individually

13. What opportunities exist for the CRS program to better integrate with other entities and/or programs? For example, in what specific ways could the CRS program better work and integrate with State, local, Tribal, and Territorial programs, including but not limited to, floodplain management, emergency services, land use planning and building code administration capital improvement, transportation, redevelopment, pre- and post-disaster recovery, climate adaptation, hazard mitigation planning, watershed management, and/or wetlands, riparian, or environmental management programs? In what specific ways could the CRS program better work and integrate with Federal disaster assistance programs or Federal mitigation programs?

a. There are several federal and state programs run by USACE, TXGLO, TWDB that collect similar information for floodplain management, flood risk determination, etc. It would be a better financial use of the resources to have a single database that can be shared by all organizations instead of asking communities to provide information to multiple sources.

* * *

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

TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK, editor, [email protected], Springfield, Virginia; 703/304-1897; https://targetednews.com