Tetra Tech Project Manager Issues Public Comment on FEMA Notice
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* I do not understand why Specialist work communities or states they are not familiar and often do not live anywhere near the community or State. If ISO is trying to select Specialist to conduct the visits because they are more complicated it takes away mentoring for those less acknowledgeable. Specialist development is vital with not only consistency, evaluating a community program but to also understand specific State regulations. As a former ISO/CRS Specialist, development was key to get the program up and running in the early years of the CRS.
* I am very concerned about the miscommunication between the CRS Specialist and the Resource Specialist - I have two communities in FL who recertified months after they were required due to miscommunication from CRS Specialist who decided to push their Cycle to the next year. It is confusing for the community and creates inconsistency.
* The difference between several CRS Specialist approach to a visit is just too vast - Some are on a totally different level than others requiring documentation in different formats and it is not helpful. Working as a contractor now, community's comment "we never had to organize documentation that way before." Or "why can't they use previous documentation submitted at the last Cycle as nothing has changed." Some Specialist will accept or supplement documentation from previous Cycle visit, others refuse.
- I am sure you will receive a comment about how cumbersome the documentation requirements are each Cycle - that has been the case since the beginning of the program however, what if you offered previous documentation as a "support" to lessen the next Cycle visit?
* New suggestion is a "Cycle - No Change" visit. Still conduct a virtual or in-person visit however, if nothing changed such as FRB or flood ordinance, you only request select activity logs, outreach copies (or use documentation from annual Recertification) to lessen the heavy documentation load. CEO must sign off of course but it might help with the many "burdensome doc requirements."
- It could off-set submitting the same exact documentation ISO likely has on file. Understanding not every activity could work this way, but for 520/530 when nothing has changed or very little to add, would save a ton of time. You still need current logs - I get it. I suggest offering documentation when "nothing changed."
* I am not sure PC / Tech Coordinators are "tagging along" with CRS Specialist as they did in the past (understanding COVID changed many things last year) but the varied approach of inconsistencies will never be observed by those who could correct this issue.
- It all boils down to lack of consistency between Specialists, PC Techs and Plan reviewers. In working with several Specialist's, the difference in collecting and the presentation to the community is varied.
* I am very concerned about the "lack" of offering communities support. One Specialist mentioned in a visit to the community (virtual) I like to process files quickly so I can earn a bonus. Obviously, that was inappropriate, however it speaks to another issue communities often mention and that is the lack of support by ISO. Sure, you field deploy CRS classes, there is EMI, you have video's, but nothing can replace the one on one sit down with a community. Not everyone can attend various conferences where one on one support is provided. This should not impact a Specialist productivity. Consider it business development opportunities, you might actually get a modification out of a visit.
* Why does a Specialist wait till almost the last week within a 30 day window for missing documentation post virtual visit to make comment? Is it not possible to conduct a courtesy review of documentation post visit in order not to wait till last week to acknowledge there is still missing documentation or what was provided was not sufficient? I have been advised a Specialist could have many files open at one time - I understand but it might not take one hour to do a quick review to determine additional documentation needs to be provided. Waiting on the last hour to review what was provided closes the window quickly.
* This EC computer scan is a problem. Looking for errors is another inconsistency. I have seen some reviews and the computer scan is not 100%, as you likely know however, whey is the Resource Specialist missing these problems? I am not totally sure how to suggest a change here especially with RR 2.0. I do like the CCMP requirement for 310, very good change. Does anyone review the CCMP?
* Obviously RL access is a huge problem that ISO likely is unable to address due to
* I would like to suggest credit for a
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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0021-0001
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