Valley Water Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 22 -- Valley Water, San Jose, California, 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. 20, 2021:

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* CRS participating communities should have the ability to regionalize activities/elements to allow for maximum participation and credit among multiple communities. Currently, communities must submit documentation from their individual communities for CRS credit. We recommend for the CRS program allow for communities to work together to submit regional documentation where all the participating communities qualify for CRS credits.

* FEMA should offer grant funding for a CRS regional coordinator role for multiple CRS participating communities. The regional coordinator role would include functions such as coordinating training, verification cycle prep and review, and CRS credit review and support to the regional community.

* The criteria to join the CRS program for communities should be lowered. This will allow for greater participation among smaller sized communities. Currently, the process to enter the CRS program requires a 1-2-day Community Assistance Visitation meeting with FEMA, where they tour the offices and review the entire floodplain management process. FEMA then discusses with staff their understanding of the community's floodplain management ordinance, knowledge of interpreting the FIRMs and FIS, how staff address customer inquiries, floodplain development permitting process, building construction plan, check and change work order processes, construction inspection and enforcement process, elevation and flood-proofing certificate completion process, SFHA violation and compliance process, substantial improvement/ substantial damage process, Letters of Map Change (CLOMR/LOMR) process, etc.

We recommend creating a lower criterion for smaller communities, as they may not have staffing to support the comprehensive floodplain activities as a larger community.

* FEMA should also consider setting a lower criterion for earning credits in the CRS program for smaller communities. Their staff size and capabilities are limited, and they choose not to join the CRS program, as it will tax the workload of their staff.

* For Activity 530 Flood Protection, flood protection projects that remove areas from the flood zone should receive credit. Currently, communities will not receive credit for projects that protect less than the 25-year flood level. A flood protection project that completely removes an area from the flood zone should be the goal of our communities and flood protection work. It should be acknowledged and credited in the CRS program.

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

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