National Flood Policy ASFPM 2015 Recommendations

National Flood Policy—ASFPM 2015 Recommendations

A. Flood Mapping 7-7-14 draft

A.1. Depict failure zones associated with dams, levees, diversions, and reservoirs on maps; where mapped mandate regulatory action, insurance and mitigation. When zone D is used to depict “Undetermined hazard” associated with Structural project, require flood insurance Include probability of failure with uncertainty bars. Also see G.1.

A.1.a Use zone D to depict “Undetermined hazard” only on lands under federal ownership such as National Parks. Also see G.1. In other areas not under federal ownership study and map the hazard. Avoid designating areas as Zone D, particularly for areas “protected” by levees.

A.2. Account for geologic/geomorphic hazards on flood maps, including fluvial erosion /channel migration zones. Channel migration zones have key relevance to endangered and threatened species habitat requirements, e.g. salmonids, as well as building safety.

A.3. Include all known coastal hazards (coastal, erosion, subsidence, sea level rise, storm surge) on flood maps, using a 150 years-into-the-future standard. These should be based on current medium to high GHC scenarios. Current estimate of average U.S. residential structure life is 150 years. Also see L.3

A.4. Include special hazards in producing FISs and on FIRMs (subsidence, sea level rise, stream mitigation zones, ice jams, flash floods, closed lake basins, debris flow, alluvial fan etc.), where applicable. Also see M.1, N.1, N.2

A.5. Map and designate propertiesareas with repeat flood damage claims and adjacent areas with repeat flooding histories in all flood zones (SFHA and outside SFHA) (including flooding from stormwater) as floodplain, for regulation and insurance Effort should be made to identify and map not only specific “repetitive loss” properties, but also other adjacent areas with documented, repeat-flooding histories, whether or not they technically meet NFIP repetitive loss or severe repetitive loss definitions. NFIP should institute a surcharge for every claim or so, similar to auto insurance. Repetitive loss properties can serve as key locations for investigations on “repetitive loss areas.” Also see G.10

A.6. Allow non-regulatory products or other simplified processes to be used as a better way to assign flood risk for insurance purposes, either through separate map or other means, then use flood maps for regulation/planning/management

A.7.(a) Fully fund and implement National Flood Mapping Program (NFMP) as directed by Congress in the 2012 NFIP Reform

A.7. (b) Fund map maintenance and regular map updating as continuation of the National Flood Mapping Program and Risk Map MAP

A.8. Continue to fund flood mapping & maintenance outside of NFIP policy and fee budget to the full authorized BW-12 levels ($499 million/year).

M&ES Comments

ASFPM draft national flood policy National Flood Policy—ASFPM 2015 Recommendations

A.9. Utilize and implement the appropriate recommendations of the new Technical Mapping Advisory Council; Consider establishing TMAC as a long-term or permanent council

A.10. Revise the NFIP requirements to require or provide incentives (e.g. CRS) for communities to establish GIS layers for subsidence (as part of the 100 year standard), where subsidence poses a flood hazard.

A.11 (a) Develop a coastal A Zone definition and provide that definition in the CFR.

A.11. (ab) Produce coastal bathymetric maps and integrate with coastal topographic maps to produce maps depicting storm surge, increased water surface elevations, reach of flooding in coastal A Zones— Multi agency effort. Also see L.17

A.11 (bc) Map and change the V-Zone standard from 3’ breaking wave to 1.5 foot waves in 1-percent chance event as supported by FEMA research and analysis.. Depict Establish a standard to base V-Zones and Coastal A Zones based on future conditions and best available science and data; require NFIP regulations and insurance to reflect this standard

A.12. (a) Delegate authority and funding for mapping of all coastal and riverineflood hazards on NFIP flood maps to qualified states and local partners under the Cooperating Technical Partners program. Program should require the authorized states and local partners to undertake the mapping in accordance with standards that equal or exceed FEMA’s standards.

A.12. (b) Require CTP delegated states to develop and maintain an archival system for all flood map models for data stewardship and storage in addition to the Map Service Center. Encourage and incentivize all states to archive flood map data.

A.12.(c) As an alternative to the current mapping program, and for sustainability of the program, FEMA could focus its attention to completing and maintaining a fully digital national flood hazard layer (rather than trying to maintain flood “maps”) and leave the updating, maintenance, and stewardship/ management of topographic data, base maps, political boundaries, or other data layers of interest to other federal and state agencies. FEMA should maintain meaningful links to these other data sets, possibly utilizing ISBN, doi, etc. Data sets should be available at least until any references to them would be for only historical purposes rather than legal, insurance, purposes, etc. A “map”, suitable for each purpose (such as flood insurance, floodplain development management, zoning, etc.), can then be assembled by each local state or entity and printed on demand; incentives will be needed for this to happen

A.13. Increase use of CTPs for delineating all coastal and riverine hazards on maps

A.14. Delegate authority to review LOMRs toExpand the LOMR Delegation Program to allow additional qualified states and state designated local authorities, with local review/sign off as needed Also see S.4

M&ES Comments

A.15. Produce all flood maps in geospatial data format & allow all such data as a substitute for traditional paper products ; require LOMRs to be in the same geospatial format, including updated databases

A.16. Map floodplains to the upstream source Also see G.2, T.8

A 17. Make past flood maps readily available in digital, electronically-transmittable format. As a first step, identify known maps not yet available electronically. However, this initiative should only be a priority when the National Flood Mapping Program is fully funded to the $400M/year level.

A.18. Develop a standard to allow for determining the ‘best floodway modeling practices’ in areas where existing standards may not be suitable. The new standard would allow for states and communities to evaluate the options and determine the best floodway definition for the specific area. This would require that certain minimum standards would be maintained, but would allow for addressing non-conforming areas, allowing usage of unsteady and 2D models and other tools to better depict the flood hazard.

A 18.(a) Map floodways based on no cumulative flood rise (zero-rise) and no adverse impact on other properties

A.18. (b) In preforming performing flood studies where the levee is assumed to contain the 1% chance flood, use the top of the levee or landward toe of the levee as the landward edge of the floodway.

A.19. Map floodways based upon a combination of depth and velocity of the water to show the true hazard and risk to property owners and communities; include as a standard NFIP flood map product

A.20. Map floodways using unsteady flow models to account for the loss of storage. Alternatively, if steady flow models are used for floodway determination, the hydrologic impacts of lost valley storage, due to encroachments should be analyzed and floodways adjusted accordingly.

A.21. LiMWAs should not be optional and should be used included on all coastal maps.

A.22. V-Zones should be mapped on all the Great Lakes, as well as the special hazard of ice.

A.23. An informational layer should be provided to all communities downstream of a dam showing the SFHA flood risk assuming the dam is removed.

A.24. Produce Develop and standard for and produce future conditions mapping that includes all scientific and planned projections of sea level rise, increase in riverine rainfall, watershed changes, etc due to development and accounting for watershed development regulations that are in place.

A. 25. Revise and update flood flow calculation guidance in bulletin 17 B to reflect the recommendations to the Subcommittee on Hydrology to produce updated Guidelines for Determining Flood Flow Frequency titled Bulletin 17 C. Page 3 M&ES Comments

A.26 (a) Required participating communities to provide update corporate boundaries within 6-months of any annexation or change.

A.26.(b) Encourage FEMA to implement a digital solution to updating layers and basemap information (such as corporate boundaries, etc) with a reference a layer that can be routinely updated.

A.27 Establish new flood zones and mapping standards for areas protected by flood control structures, relates to I.8.

A.28 Revise protocol to allow for the final products be map layers, not maps. Layers should have supporting metadata, domain tables, profiles, etc. See also A.12.

A.29 Express horizontal accuracy standards in terms of standard deviation (hyperlink: NIST).

A.31. Let each kind of information be stored in its own raster.

B. Hydrology & Hydraulics B.1. (a) Account for flood depths and velocities in setting zones and insurance rates; new charts or tools should be provided to insurance agents to streamline rate selection, relates to A.19

B.1. (b) Provide flood depth grids as part of the FEMA flood map series and require encourage communities to adopt those maps for administering the NFIP requirements in their community. Encourage CRS incentive credits for this activity.

B.2. Automate data inputs and update USGS regression equations using updated geospatial land cover and gage data.

B.3. Use Doppler rainfall data more effectively in flood flow predictions

B.4. (a) Incorporate future-conditions hydrology and cumulative impacts into flood risk determinations under the NFIP. Flood insurance studies should identify assumptions for hydrologic estimates, especially for future conditions; adjust planning and regulation to avoid transferring the responsibility from those that cause the problem to those that suffer the consequences.

B.4.(b) Ensure that the cumulative impacts of encroachments be incorporated into all flood risk determinations such that there is no resulting increase in flood elevations without associated mitigation actions, such as purchasing flowage easements, buying flood insurance for affected properties and purchasing and relocating affected buildings.

B.5. Fund and issue updates of National Weather Service regional rainfall frequency curves

M&ES Comments

B.6. (a) Develop engineering models that are properly calibrated to historic flood events where available to reduce the uncertainty associated with the model results before such models can be deemed validated. .

B.6. (b) FEMA needs to establish guidelines and quality assurance protocols for evaluating the unsteady and two-dimensional models, reporting requirements appropriate for these modeling techniques, and for the development and review of floodway boundaries derived from such models.

B.7. Ensure thatPromote engineering models that are open source, public, user-friendly, and widely accepted. This goal should not prevent the use of legacy software where appropriate. Also, model performance should not be sacrificed for user-friendliness.

B.8. Calculations of flood flow frequencies should be determined based upon a 95% confidence level (if feasible) to reduce the uncertainty in associated flows used for flood risk determinations. Model convergence and sensitivity analysis are prerequisites to the estimation of meaningful confidence levels.

B.9 Use the 1% chance flood plus future conditions and freeboard for mapping and regulation

C. Stormwater Management C.1. Emphasize integration of water quality and quantity (flood loss reduction) programs and fosterRecommend or require holistic and no adverse impact stormwater approaches at state and local levels for the reduction of runoff for the reduction of flood damage throughout watersheds, and for the protection of water quality and groundwater recharge.

C.1(a) Emphasize and foster the integration of water quality programs within all watershed management approaches at state and local levels.

C.2. Consider both flooding and water quality in all FEMA HMGP and Environmental Protection Agency Section 319 demonstration projects

C.3. Require critical facilities to consider and quantify both mapped flood risk, but alsoand the potential for increased risk due to land use changes and climate change by quantifying watershed and stormwater runoff that affects the site with respect to the design life of the facility.

C.4. Encourage/incentivize (CRS and other) rainfall, runoff reduction and runoff infiltration, low impact development and green infrastructure techniques to reduce and manage flood flows and runoff, to help in protecting water quantity and water quality.

C.5 Apply and expand NFIP Community Rating concept to allow EPA and FEMA to credit community actions to reduce stormwater and urban flooding risk and to improve water quality and green

M&ES Comments

ASFPM draft national flood policy National Flood Policy—ASFPM 2015 Recommendations infrastructure. Credits could come in form of advantageous sliding cost-shares for grants, disaster assistance, or other incentives.

C.6. Encourage or require watershed management that prevents an increase in flood flows by new development or redevelopment with attention to the via control of not only peak flows, but also the volume of runoff and the timing of runoff.

C.7. Wetlands and other storage areas outside of the SFHA should be preserved to prevent downstream increases in flood frequency and heights.

C.8. EPA, as part of MS4 permits should require the control of the peak and volume of runoff to the 1% annual chance event , or greater than the 2-10 year events to prevent the erosion of stream channels, pollution, and damage to adjoining structures which creates more pollution.

C.9. Consider requiring building setbacks/buffers from all streams and coasts with that area preserved in their natural state to reduce flood and ecosystem damages and preserve water quality.

C.10. EPA guidelines for watershed management plans should include the impacts of flooding and the impacts of development and the hydrologic regime and flood risk.

C.11. As a prerequisite for Class 4 CRS communities must require all new development and redevelopment to fully use LID techniques to the maximum extent possible for each site to mitigate their impact.

D. Water Quality See C. Stormwater Management

E. Data & Technology E.1. Provide reliable funds for stream gaging and identify additional funding sources for stream flow data gathering and analysis. and encourage local participation in funding the gage system. Establish an intergovernmental commission for recommendations to meet these goals. With increasing evidence of changes in climate and rainfall patterns, the enhancement and strengthening of the nation’s stream gaging network and stream flow data collection is becoming critical for flood risk management and long-range emergency and watershed planning and standard setting.

Also phrased: “Provide funds for streamgaging. Fully fund the NSIP and provide frequent updates of stated regression equations.”

Also phrased: “Provide federal and over funds for streamgages.” Page 6 M&ES Comments

E.2. Fund and update and maintain list of critical index stream gages (NSIP) nationwide—federal funding of this network is essential.

E.3. Develop mechanisms by which NWS/local warning systems can supplement stream gage data to help in the forecasting of stormwater and urban flooding.

E.4. Place all data collected post-disaster (including NFIP claims information) in public domain and easily accessible to states, localities, researchers & stakeholders; in real time Comment: the claim of “privacy” of much NFIP individual and geographic area data and the consequent continual state of public confusion over costs and trends for 45 years has substantially retarded necessary research and analysis to assist the improvement of many aspects of the NFIP and disaster program. A major policy shift is needed in this area. Encourage the consolidation of information protected under Privacy Act into census block level data or some similar aggregation of data so that it is useful for planning, analysis and research to assist in the improvement of the NFIP, flood risk communication and disaster response.

E.5. Develop open-source tools for post-flood damage estimation

E.6. (a)Collect nationwide data on the number of floodprone structures, dams & levees, population at risk. New law (BW-12) requires such data as well as other critical data to be both collected and incorporated by FEMA into future flood insurance rate maps. TMAC can suggest means of collecting and incorporating data, however, FEMA is required to carry out these requirements. Also see I.11

E.6. (b) The federal interagency group Mit FLG, in consultation with state and local partners should discuss a continuing process and key roles in how to collect, aggregate, analyze and operationalize the collection and use of such data in the NFIP, flood damage reduction, disaster assistance, and other federal construction, development, planning, funding and technical assistance programs.

E.6.(c) Nationwide LiDAR is needed for the entire nation with flood mapping being one of the major uses of that topographic data since updated, accurate topo data is needed with adequate modeling in order to produce accurate flood maps. Funding sources can be a combination of different federal sources, along with state and local sources in order to reduce duplication of effort

E.7. (a) Generate complete list of number and location of residual risk floodplain buildings and infrastructure and levee-protected buildings and infrastructure nationwide by making community participation in NFIP, CRS, disaster assistance, HMGP grants, approval of local hazard mitigation plans, and the Corps of Engineers’ Rehabilitation and Inspection program, (P.L. 84-99) contingent on community’s supplying and periodically updating that information

E. 7. (b) Collection of the data on residual risk structures and infrastructure could be eligible for cost share funding from HUD, FEMA and other funding sources.

M&ES Comments

E.8. Establish nationwide database on disaster costs and the benefit/cost ratios of mitigation, organized by stream reach or shoreline as designated by the National Hydrography Dataset or State or Regional equivalent thereof. Track relative disaster costs and responsibilities by levels of government and sectors. This data is needed because Federal costs for disasters are skyrocketing on a path which rivals the long- term unbudgeted imbalance in the U.S. social security system – potentially in trillions of dollars; average federal share has risen recent decades from modest percentages to 70 percent in recent major disasters. Data needed to better document costs, trends and values of mitigation. See Q 19

E.9. Determine the true cost of disasters by developing a mechanism to account for all the direct and indirect costs of a flood disaster. Increasingly, it appears these cost may be 10 times greater then than current estimates.

F. Floodplain Development Standards, Regulations and Codes F.1. (a) FEMA should work with state and local floodplain managers partners to achieve comprehensive revisions to NFIP regulations (e.g.. freeboard, no-rise floodway, redefine coastal A zones, elevation certificates for all; critical facilities protection; substantial damage; better storm surge information for coastal A Zones) recognizing and taking into account adaptation requirements for climate change and sea-level rise, and seeking public and stakeholder comments.

F.1. (b) Promote NAI based development standards in the base International Construction Codes (ICC) codes as well as the ICC green codes

F.1.(c) Require participating states and their communities to adopt the IRC and IRC without exception or change. (In several states the provisions for determining substantial damage/substantial improvements has been omitted. This has resulted in 1-story, 2-bed cabins in the V-zone being converted to multi- story, $multi-million homes at-grade.)

F.2. Evaluate CRS activities to determine which ones should be made minimum requirements under the NFIP regulations: This could be billed as an immediate step toward F.1

F.3. Require mitigation measures (elevation, zoning, insurance) in failure zones associated with dams, levees, diversions, and reservoirs to reduce residual risk and taxpayer costs

F.4. Revise NFIP regulationsEncourage adoption of flood ordinances that to require 2 or more- feet of freeboard above BFE for new construction in riverine areas and 3-4 feet of freeboard in coastal areas

F.4.b Require the use of the 95% confidence level for all mapping and regulations of SFHAs, and for level of protection calculations for all flood control structures

M&ES Comments

F.4.c Require the use of the medium credible projection of sea level rise by 2100 for all mapping and regulation (also for the expenditure of any and all federal funds, construction and technical assistance.

F.5. (a) Revise NFIP regulations to require a no rise, no adverse impact on other properties floodway (apply this no-rise to LOMCs and LOMRs also) No development would be allowed to create a rise without compensating those impacted. (See F.7, F.8 and F.9) make clear that this policy is based squarely on fairness to other land owners, land users and occupants, and on public safety and protection and maintenance of important and valuable floodplain functions.

F.5. (b) No habitable structures should be allowed in the floodway; however, accommodate existing structures and structures impacted by channel movement.

F.6. Revise the NFIP regulations to define critical facilities, prohibit them in regulated floodplain unless no alternative exists and they are elevated to above 0.2% annual chance 500-year level with freeboard and estimated future conditions incorporated, require 500-year0.2% annual chance protection with including access and operability during the 0.2% annual chance 500 year event, and set other standards as needed It may be practical to prepare and implement plans to provide the services of a critical facility at an alternate location or in spite of the event. It may be more economical to provide numerous, smaller, distributed facilities, each of which may be at risk for lesser events, but where it is unlikely that all of the facilities would be unavailable during an event. Requirements for critical facility should respect the warning time of the events from which the facility is being protected. Design for protection from hurricanes (warning time: days) might yield different results than design for protection from flash flood (warning time : minutes to none). Also see J.1–7

F.7. Rewrite or issue guidance to simplify and standardize compliance with 44 CFR 60.3(c)(10), which requires consideration of cumulative impacts on flood elevations to ensure the cumulative impacts of encroachments into the mapped SFHA cause no increase in any frequency flood elevations, velocities, erosion or other adverse impacts unless all impacts are agreed to by all impacted property owners through mitigation actions or purchase of easements. This process should allow use of verified non- published BFEs.

F.8. Revise the NFIP regulations to require initial floodplain mapping that matches topography for all USGS blue line streams in subdivisions and large scale developments, and that the map be based on a hydraulic model that includes a floodway analysis or other approved cumulative impact of encroachments analysis

F.9. (a) Revise the NFIP regulations to lower the threshold of “large” developments required to submit 100-year1% annual chance flood data (and recommended floodway analyses) Explore alignment of thresholds with requirements of the CWA.

M&ES Comments

F.9. (b) Require that all new subdivision lots created have enough natural buildable ground above the BFE to contain the entire building envelope during platting. This would not be applicable to special types of construction, such as when building on pilings.

F.9.(c ) Require that when a community has adopted subdivision regulations, that the regulations be revised to contain required platting and development standards if not already required by a state.

F.9. (d) Require improved stormwater management standards for all new subdivisions that address lower frequency events (50 or 100-yr events vs. 2- 5-year events)..

F.9. (e) F.25. Require that all newly platted subdivisions clearly identify all known flood hazards and related natural hazards (e.g. subsidence, erosion, dam or levee failure, sink holes, etc), but not necessarily mapped to the parcel level. To avoid a duplication of effort, hazards can be incorporated by reference.

F.10 (a)Develop and implement effective monitoring, probation and suspension guidance and standards for better NFIP compliance for all NFIP participating communities.

F.10 (b) For all new structures in coastal zones, or everywhere, the community must be allowed to inspect properties at will to ensure compliance, and especially at any transfer of the property.

F.11. Revise the NFIP regulations to include identification and management measures for subsidence related to flood risk management. Also see N.2

F.12. Revise NFIP regulations to prohibit unmitigated fill anywhere in the SFHA, or at a minimum revise NFIP regulations to prohibit fill for elevation in coastal A zones See F.13

F.13. Revise NFIP regulations to prohibit septic systems in V zones

F.14. Revise the NFIP regulations to prohibit or heavily restrict the use of fill for triggering Letters of Map Change and changes in flood insurance rating. (duplicate)

F.14(b) The use of fill should be considered an acceptable elevation technique, but not justification for a LOMR. In almost every case the property is still within the SFHA and subject to flooding. Moreover, if a LOMR-F is issued, the property owner can purchase flood insurance at the ‘preferred risk’ rate. Standards need to be developed before fill can be considered to be outside of the SFHA. For example:

 3’ (or more) above BFE

 2’ (or more) above 500-year

 Contiguous to lands outside of the SFHA (to eliminate approving islands in the middle of the floodplain)

M&ES Comments

 Adequate protection against erosion

F.15. Revise the NFIP regulations to require local ordinance to require local floodplain administrator or building official to define specify that they are responsible to determine substantial damage.

F.16. Revise the NFIP regulations to require cumulative substantial improvement over the life of the structure. see R.8

F.17. Revise the NFIP regulations to require buildings in coastal A Zones to be designed and constructed to V zone standards to be more resistant to coastal flood forces. This will require an update to the design and construction standards.

F.18: Evaluate CRS program to recognize more mitigation actions as eligible activities and to increase points for activities that result in the greatest mitigation benefits.

F.18 Revise the NFIP regulations to map and regulate an erosion zone with rolling building setbacks and require all communities to adopt that. 44 CFR 60.1(b). The regulatory standard should incorporate likely future conditions and reflect the expected useful life of building constructed or substantially improved

F.19 Revise the LOMC requirements to require an Environmental Assessment in all instances to ensure endangered species are not impacted.

F. 20 Establish NFIP regulations to ensure Endangered Species Act (ESA) compliance with development, LOMC’s LOMR-F and addresses other structures with impacts on threatened and endangered species and critical habitat.

F.21. Promote NAI based development standards in the international green construction code.

F.22. Require V Zone construction standards in coastal A Zones.

G. Flood Insurance G.1. Require flood insurance in 100- and 500- year floodplains, storm surge zones, erosion zones, and residual risk zones associated with structural projects (preferred risk rates for latter), including those behind levees.

G.2. Discontinue practice of waiving the flood insurance requirement after issuance of LOMRs, LOMR-Fs and LOMAs; apply risk-based rates F.5, K.15, T.8

G.3. Ensure the movement to actuarial rates over time continues for non-primary residences as per BW- 12 –

M&ES Comments

G.4. Gradually eliminate grandfathered rates over time by having a surcharge of x percentage after each claim of more than some percent of value or by charging actuarial rates once a damage claim is paid

G.5. Movement of insurance rates toward actuarial must be balanced with increased tools, assistance and funding for mitigation to help homeowners and small businesses with affordability of insurance. This could include means tested vouchers, credit for mitigation or others means, but must be done carefully to ensure it does not increase the moral hazard.

G.6. Create more stratification in insurance rates to reflect the variety in risk within flood zones; this must be linked to providing tools to insurance agents to simply how they can correctly rate a policy. The current NFIP approach that results in rates for some shallow flooded structure to be the same is deeper flooded structures does not encourage mitigation or development in lower risk areas.

G.7. Apply mandatory purchase requirement to non-federally regulated mortgages or require that lender to pay the claim

G.8. Ensure compliance with NFIP mandatory purchase requirements; at every-year anniversary of mortgage, and upon transfer; ensure penalties are applied for violations.

G.9. Revise NFIP regulations to make zone changes effective immediately, without regard to lender notification or changes in status of mortgage

G.10. Map any structure outside the SFHA for which two or more damage claims are paid as a floodplain structure so that insurance is required and regulations apply; also increase the rates 20% with each claim Also see A.5

G.11. Implement law that allows FEMA Director to impose use of ICC when beneficial to NFIP Fund

G.12. Promulgate insurance rules to financially neutralize repetitive loss properties through actuarial rates, deductibles, or by actuarial rates if mitigation is not done after any offer; incentives can be a part of this effort

G.13. Set up a procedure by which the NFIP compliance of a structure is automatically verified after a claim is paid for substantial damage or even a second or third claim, this should be used for eligibility in CRS and NFIP? (CAV)

G.14. Continually Evaluate CRS to ensure that activities that merit rate reductions are reducing losses

G.15. (a) Establish clear and rigorous audit procedures for CRS communities compliance, and do this on a set schedule, especially post-disaster, but also for auditing on a regular basis. CRS compliance is essential and must carry penalties for non-compliance. All policyholders pay for CRS credits whether in CRS community or not, at a cost of over $200 million per year.

M&ES Comments

G.15 (b). Require EC’s for all new floodplain permits and require that the community keep copies.

G.15 (c). Examine potential for community based insurance, multi-year policies purchased by and for the community at-large and based on actual risk.

G.15 (d). FEMA disaster program could offer or work with the reinsurance industry to offer communities insurance for their infrastructure and disaster assistance in general. It should be required of all communities and could be subject to the CRS discount. It would cover roads, bridges, waterlines, sewer, stormwater, power, telecommunication, treatment plants, debris removal, - basically everything now covered by PA.

G.16. Continue marketing campaigns for both purchase and renewal of flood insurance policies; target marketing to homeowners without mortgages

G.17. FEMA should significantly expand the agent training provided by NFIP Training Contractor, both the number of courses and topics (i.e., legislation changes, ICC, mitigation options, non-reg products like depth grids, Changes Since Last FIRM. This should also support agent training that incorporate floodplain management, flood mapping familiarity , and mitigation, and to require continuing education for license renewal by end of 2015

G.18. Use outreach, monitoring, and other measures to enforce the NFIP requirement to identify and insure state- owned and locally-owned floodprone structures, with required pay back to the federal treasury and NFIP for non-compliance

G.19. Improve working relationship among floodplain managers and insurance industry, with FEMA and the professional organizations assisting in fostering this relationship

G.20 Modify the NFIP to require mapping and management of and to provide erosion/mudslide coverage only where those hazards are mapped and appropriately regulated, possibly via a surcharge

G. 21 Establish additional levels of risk zones, or add a surcharge for flood insurance for floodways (analogous to V Zone ratings) for maps and flood insurance

G.22 Establish higher rates for structures in high velocity or erosion prone riverine areas.

G.23 Review the existing policy base, and continually perform Quality Assurance, to ensure structures are shown to be within the appropriate community to prevent policy holders from receiving an inappropriate CRS discount.

G.23(b) FEMA must issue LOMRs to reflect community boundary changes due to annexations within 60 days of receipt of revised corporate limits.

M&ES Comments

G.24. Establish a requirement that by 2020 all owners of insured structures must obtain Elevation Certificates and place on file with local governments and with FEMA. FEMA, working with local governments, provides incentives to implement. Provide CRS credits for communities who do this for all floodprone structures; also allow use of other cost share funding for this

G.25. Ensure actual cost of flood insurance is communicated clearly and directly to all policy holders each year, regardless of discounts or subsidies

G.26. Require signoff of all claims over 25% or similar threshold by community floodplain administrator as part of claims processing for substantial damage determination and mitigation

G.27. Allow communities direct access to claims data as they are being processed for use in regulatory processes

H. Mitigation H.1. Create incentives to encourage incorporation of no adverse impact in mitigation plans, state/local regulations, and land use planning.

H.2. Produce and release an annual ICC report on funds expended, mitigation implemented, and reserve balance

H.3. Expand ICC to allow assignment of claim to cover acquisition of damaged buildings as a means of compliance, if the damaged structure is then destroyed or rebuilt in compliance.

H.4. Increase maximum of ICC coverage to $50,000 with an inflation factor and adjust policy fee as necessary for costs; allow ICC claims over $50,000 by creating a sliding scale that requires match funding or other mechanisms that ensure cost control

H.5. Implement law that allows FEMA Director to impose use of ICC when beneficial to NFIP Fund and relax triggers for eligibility requirements of ICC claim eligibility so more structures can qualify (RL, SRL, etc.) see G 11

H.6. Expand incorporation of ecosystem services and credits in benefit-cost analyses in all agencies methods for non-structural mitigation including open space and land use approaches that reduce flood damages

H.7. Establish permanent authorization for Corps to conduct nonstructural floodproofing projects; increase funding for existing Corps nonstructural programs

M&ES Comments

H.8. Continue to update FEMA B/C procedures to update depth-damage functions and include all social and ecosystem services benefits

H.9. Streamline and institutionalize methods for delivering mitigation assistance and funding after flood disasters

H. 10. Train FCOs, PA and IA field staff to require post-disaster mitigation and incorporate into all- hazards mitigation plans Also see O. 15

H.11. Keep HMGP funding at 15% of disaster costs, with 20% for states with enhanced mitigation programs

H.12. Write rules to implement HFIAA, BW-12, DMA2000 provisions for severe repetitive losses, delegation of HMGP, and ICC

H.13. Track all repetitive loss information in databases to identify location of building and cause of flooding, and share information with state and local partners on a real time basis. See E 4

H.14. Transfer administration and oversight of HMGP, FMA, and PDM to qualified states

H.15. Change date for inclusion of eligible costs under HMGP to the date of disaster declaration.

H.16. Periodically (3-5 years) conduct an independent evaluation of mitigation programs including PDM, HMGP, FMA to quantify their effectiveness in reducing losses Also see E.9

H.17. Evaluate mitigation plans of communities hit by a disaster and summarize lessons learned and evaluate effectiveness of mitigation plans.

H.18. Require state and local mitigation plans to incorporate consideration of cost-effective mitigation measures for infrastructure to be implemented post-disaster

H.19. Cross-train code officials and floodplain managers in building code-flood loss reduction programs

H.20. Increase cost share assistance to states and communities that meet and go beyond the International Building Codes and NFIP regulations: an alternate; Reduce disaster and mitigation funding for states and communities that follow only the minimal International Building Codes & NFIP regulations.

H.21. Build state capability for mitigation by developing a FEMA/State partnership program for mitigation modeled on the CAP program

M&ES Comments

H.23. Ensure funds from all FEMA mitigation grant programs are used for non-structural mitigation and not structural flood control, which is the purview of USACE

H. 24. Collect and disseminate stories of local and state success in hazard mitigation; include demonstrations of positive impacts on flood insurance

H. 25. Require state and local hazard mitigation plans include emergency action plans and consider adverse impacts on other properties and communities Also see I.9

H. 26. Encourage states and communities to develop holistic mitigation plans that will contribute to community resilience and sustainability of their economy while integrating multiple federal programs with a comprehensive review process

H. 28. Establish online database of state and local mitigation projects organized by type of mitigation project

H.29. Require state and local mitigation plans to focus on local capabilities and what they can and will do, with no federal funding. Require them to plan to create internal capability.

H.29. Require a high-level federal interagency (MitFLG?) follow-up review of causes, costs, impacts, policies, and mitigation response for all major Presidentially-declared disasters.

H.30. Create (or utilize existing programs in HUD, SBA, etc.) low cost loan mechanisms to ensure all homeowners and small business owners have access to mitigation funds which can be spread over time

H.31.Deploy nonstructural mitigation workshops in disaster areas during the initial recovery phase

I. Structural Projects I.1. Use structural flood control projects only as a last mitigation resort & never to protect undeveloped or added value development to “protected” land.

I.1(b). All lands and property “protected” by structural flood control projects must remain within the SFHA and required to be regulated and insured. The lands should be designated on FIRMs as AL (for “levee”).

I.2.(a) Build all structural flood control measures to 500-year protection (to protect federal taxpayer investment and insurance) even if B/C is cost effective at 100 year.

M&ES Comments

I.2. (b) Grandfather structures that provide between 100- and 500-year protection, based on current and estimated future conditions hydrology, and make preferred risk insurance available. Develop a mechanism to upgrade those structures to 500-year protection

I.2. (c) Revise automatic method of estimating benefit claims of previously constructed projects, based only on river elevation fluctuations.

I.3. Prevent or mitigate any adverse impacts (social, economic, environmental) from construction, repair, rehabilitation of structural projects prior to construction of the project

I.4. (a) Require local sponsor of structural flood control projects to demonstrate financial and technical capacity for operation and maintenance before project approval or recognition of levees and all structural and non-structural measures by NFIP, USACE or PL 84-99

1.4. (b) disallow reimbursement of local sponsor expenses that are used to build water resources projects before the Administration has approved and Congress has authorized the project

I.5. Oversee and enforce ongoing operation and maintenance of structural and non-structural measures as a condition of federal support or deny/remove the project from PL 84-99 program

I.6. (a) Use watershed-based planning and coordinate programs when developing water resource projects and require full analysis and evaluation to include nonstructural components

I-6. (b) Increase emphasis and establish incentives for the use of non-structural approaches in water resources development and flood risk management programs through revised Principles, Requirements and Guidelines and other planning tools.

I.7. (a) Perform environmental restoration of natural functions prior to or during repair, rebuilding of structural projects and implement nonstructural complements

I.7 (b) Require full analysis and consideration of removing a structural project as an option to significant repair or upgrade.

I.8. Map and require flood insurance (rates based on residual risk) and mitigation measures for all building/development in failure zones associated with dams, levees, diversions, reservoirs

I.9. Require communities with NFIP-recognized structural flood measures to have a multi-hazard mitigation plan and an emergency action plan Also see H.25

I.10. Moved to I.2. (b)

I.11. Inventory and build database of levees (public and private), general condition, and potentially at- risk development nationwide (number of structures and people) Also see E.7

M&ES Comments

I.12. Estimate useful life of existing flood control structures nationwide; develop strategy to inspect, maintain, repair or remove

I.13. Agree on definitions of levees (and other structures) that incorporate consideration of function, risk, and vulnerability

I.14. Set levees back from riparian area, to reduce erosion and scour, reduce flood levels and allow natural ecosystem to serve their functions Also see K.12

I.15. Stand up the National Levee Committee of federal agencies and state/local partners to revise/develop levee design standards to build in resilience, e.g., freeboard, spillways, etc.

I.16. (a) Develop guidance and training on proper inspection and maintenance of levees for accreditation and recognition by NFIP; include responsibility of and consequences/liability to owner

I.16 (b) Update and revise federal emergency rehabilitation for flood control structures program (P.L. 84-99) to conform cost-sharing with other flood damage reduction programs, reduce federal disaster costs, reduce risks, and support greater use of flood risk management and non-structural approaches.

I.17. (a) Implement the federal policy that maintenance, inspection, and repair of levees is the responsibility of levee owner

I.17 (b) Ensure that project sponsors commit to and continuously meet all conditions of PL 84-99 program or remove the project from the program.

I.18. (a) Enforce the requirement that federal taxpayer funds for levee repair are contingent upon proper inspection, operation and maintenance by levee owner

I.18. (b) Develop a program to identify levees and other structures with repeated federal emergency repair and rehabilitation expenditures, and require consideration of a full suite of risk mitigation options for the structures (similar to NFIP repetitive loss mitigation programs.)

I.19. Develop a national levee safety program to be administered by states, integrated with state dam and floodplain management programs

I.20. Encourage state dam safety programs by making disaster assistance or other federal funding contingent on an effective State program; with reflective sliding scale cost share

I.21. Provide incentives for states to remove dams that can/should not be maintained

I.22. Use watershed-based, multi-objective planning to determine fate of aging dams in small watersheds

I.23. Provide technical assistance for addressing aging dams in small watersheds Page 18 M&ES Comments

I.24. Determine federal taxpayer role in addressing aging dams in small watersheds

I.25. Make public aware of residual risk associated with structures including flood depths and velocities; use signs and publicize insurance availability as minimum non-regulatory product in all Risk MAP projects.

I.26. Establish a joint federal/state/regional work group to find ways to enhance levee performance and set appropriate levels of protection

I.27. Develop consistent guidance for local and regional planning of levees and other structures

I.28. Revise federal agency Guidelines to balance the economic, social and environmental impacts of water resources projects and to account for public safety in designing flood risk reduction structures— all in accordance with the new Principles and Requirements

I. 29 Include requirements that Corps projects meet the same wetlands mitigation standards as other agencies Review whether the WRDA 2014 requirement to raise the threshold for automatic independent review of projects costing greater than $200 million (from previous $45 million) is acceptable.

I.29 (b) Review whether the WRDA 2014 requirement to raise the threshold for automatic independent review of projects costing greater than $200 million (from previous $45 million) is acceptable.

I.30. Require long term Operation and Maintenance costs be included in BCA of structural and nonstructural projects

I. 31. Require communities to relinquish all federal disaster assistance for future damage below the 100- year flood elevation in areas protected by structural measures

I. 32. As part of all structural projects, require that maps be created that are based on failure and overtopping inundation and those maps be publically available

I. 34. Require permanent deed notices on all properties protected by structural measures notifying them of protection and where to get additional information

J. Infrastructure & Public Buildings J.1. Develop national hazard resilience standards for the location, design, construction, and reconstruction of all public infrastructure and including alternative locations and taking into account factors of expected future conditions for cost effective mitigation, increases storm intensity, sea level

M&ES Comments

ASFPM draft national flood policy National Flood Policy—ASFPM 2015 Recommendations rise, etc. during the infrastructure’s expected life; these standards become a condition of federal funding

J.2. Develop guidelines and standards (including no adverse impact requirement) required for use of federal funding for local, county, and state transportation departments to use in the post-disaster repair and reconstruction of damaged roads and bridges using federal disaster funds and taking into account factors of all expected future conditions during the infrastructure expected life

J.3. Require state and local mitigation plans to identify the extent to which that infrastructure would be eligible for Public Assistance; and determine mitigation measures to reduce future losses taking into account expected future conditions.

J.4. Require utility companies eligible for Public Assistance to account for the flood risk in planning, design, construction and re-construction of facilities, analyzing the full range of mitigation options

J.6. Make Public Assistance funding contingent upon mitigation measures for any facility substantially damaged or damaged more than once in 10 years Also see F.6

J.7. Prohibit the use of federal funds to site new public infrastructure in the SFHA that would serve new development In undeveloped areas

K. Natural & Beneficial Functions/Resources K.1. Initiate a national study on environmental degradation that results from water resources development and the impact of that degradation on the economy

K.2. Based on the recommended national study (above), reformulate a statement of federal interest in water resources policy; shift to sustainability and resilience rather than economic development

K.3. Develop a resource management strategy to further federal interest in water resources

K.4. Establish a National Riparian Zone Policy Also see I.14

K.5. Determine viability of conservation easements to protect high flood risk and high resource and erodible lands in light in rising crop prices and food demand

K.6. Continue to examine the economic value of watershed ecosystem services and how to incorporate those values in all B/C analysis and flood risk and water resource management decisions. Also see P.7

M&ES Comments

K.7. Clarify Section 404 of Clean Water Act to reduce flood losses, protect riparian areas, wetlands and waters of the US

K.8. Establish and fund a permanent Environmental Restoration Program within the Corps

K.9. Adjust federal BCA methodology so the USACE and FEMA methodology are consistent

K.10. Emphasize maintenance and protection of natural storage areas in all watersheds; increase the CRS credit for preservation of storage areas anywhere within the watershed.

K.11. Encourage continuous buffer zones along all waterways and coasts Also see L. 2, L. 7

K.12. Convert Continuous Conservation Reserve Program to a permanent easement program for riparian buffers nationwide

K.13. Collaborate to integrate/produce resource mapping in conjunction with flood mapping

K.14. Direct FEMA to study whether LOMCs LOMR-Fs undermine floodplain resources Also see G.2, I.7, K.15, T.8

K.15 Prohibit fill in all SFHA to protect natural resources.

K.15.(a) Require an EA (environmental assessment) for all new floodplain permits unless the community has done previous assessment for a planning area or the entire community.

K.16 Map and protect from development highly erosive areas, including channel migration zones, adjacent to our rivers, streams and coastlines. Not only are these areas risky for development, but frequently provide some of the most valuable habitat within the watershed.

K.17 Catalog the location of all fills with the SFHA to determine their impact on natural functions, including storage.

K.18 Increase the CRS minimum points required in NBF elements that credit natural floodplain functions for CRS class 4 and 1 communities.

L. Coastal Issues L.1. Share/redirect navigation fuel tax for coastal and aquatic habitat restoration

L.2. Provide preferential support (grants and cost share) to states & localities whose policy is gradual retreat from the shoreline. Encourage all coastal states to plan for sea level rise and develop a long term plan to abandon barrier islands and low lying areas subject to sea level rise.

M&ES Comments

L.3. Establish a national policy for using a 100-150-years-into- the-future standard for all coastal management, i.e., erosion, setbacks, sea level rise, subsidence Also see A.3

L.4. (a) Avoid the use of hard structures to protect shorelines unless no adverse impact can be demonstrated; In order to support resilience, give preference to retreat or soft techniques in all funding programs

L.4 (b) Require that funding and regulatory decisions to armor shorelines include an evaluation and assignment of long-term costs to mitigate potential adverse impacts of armoring, including erosion and scour.

L.5. Enforce the protection of dunes and mangroves as required in NFIP regulations

L.6. Provide more funds for purchase of barrier islands and easements on barrier islands, leverage existing funds after a disaster

L.7. Require comprehensive planning for coastal acquisition; Require acquired lands to be dedicated to resource restoration and enhancement to increase level of natural protection, and also to promote public access to public trust lands.

L.8. Modify National Estuarine Research Reserve provisions to allow acquisition of uplands

L.9. (a) Expand the Coastal Barrier Resource System (CBRS)

L.9. (b) Review and Strengthen monitoring/enforcement /penalties for non-compliance of provisions of the Coastal Barrier Resources Act

L.10. Do not remove protected natural, wilderness or federally owned areas from Coastal Barrier Resources System

L.11. (a) Map and manage coastal erosion just like flooding, if it is to be covered by flood insurance

L.11 (b)Delineate all erosion hazard areas on FIRMs in order to increase awareness of erosion hazards and vulnerability among property owners and local governments.

L.12. Evaluate coordination among all federal agencies and coastal states of coastal zone management, floodplain management, and emergency management and identify actions to minimize conflicts, align programs and missions, and increase efficiencies.

L.13. Provide incentives to encourage coastal communities to have evacuation plans in place and/or to encourage that approval of coastal development be contingent upon provision for warning and evacuation plans Also see F.12, F.13, F.14

M&ES Comments

L.13 (b) Require warning and evacuation plans be tested annually and those tests involve businesses and the public to improve public awareness.

L.14. Plan and build highways to consider evacuation of the communities they serve

L.15. Improve public awareness of coastal risks and natural resources and functions, preparedness, and evacuation

L. 16. Improve coastal flood maps by integrating bathymetric and topographic maps to show wave runup, storm surge, erosion hazard areas, increased water surface elevations from future conditions

L.17. Evaluate the impact of making flood insurance mandatory for all buildings in coastal storm surge zones

L.18. LiMWAs should not be optional and should be used on all coastal maps. See A 21 latter is covered elsewhere

L.19. Develop a coastal A Zone definition and provide that definition in the CFR. See F.22

M. Arid Regions M.1. Develop techniques to identify the nature and associated vulnerability of arid region hazards, including alluvial fans and post-wildfire conditions

M.2. (a)Continually update flood risk mapping approaches for arid regions; due to unique flow path uncertainty in arid regions, a model capable of handling such uncertain flow path, such as those having the capability of simulating probabilistic or stochastic features, is required. Also see A.4

M.2. (b) Find ways to overcome the past problem that over the years, delineation techniques have been allowed that failed to recognize the flow path uncertainty in arid regions, thus unintentionally reducing the extent of area where the regulations applied

M.3.(c) Residential and commercial development within the Alluvial Fan areas should be avoided or highly restricted because the nature of floods in arid regions is not simply the inundation by a certain depth of water, but rather what the floodwaters are carrying and how uncertain the flow path is due to erosive forces, movable stream beds and post-wildfire conditions

M.3. Develop management techniques for arid region flood hazards, tied to the nature of the risks

M.4. FEMA should resume the needed arid regions research that was started with the 1985 DMA study and the 1996 National Academy study. (Arid Regions Committee: Make recommendations on specific

M&ES Comments

ASFPM draft national flood policy National Flood Policy—ASFPM 2015 Recommendations steps to be taken in order to characterize, identify, map, and mitigate hazardous flood processes for areas subject to alluvial fan flooding.

N. Special Flood-related Hazards N.1. Require inclusion of unique hazards (erosion, subsidence, closed lake basins, frazil ice, ice jams, tsunamis, debris flow and mud slides) in state/local hazard mitigation plans, where applicable

N.2. Develop techniques for mapping, mitigation and management of special hazards Also see A.2, A.3, A.4

O. Disaster Management & Assistance

O.1. Implement the Emergency Management Assistance Compact so that it covers key aspects of the mitigation and recovery phases

O.2. Restore FEMA to independent agency status;

O.3. Establish a National Response Plan that directs federal response but also ensures use of “discretionary” funds and the goals of long-term recovery, mitigation and redevelopment

O.4. Make the availability of and amount (sliding-cost-share)of disaster assistance contingent upon taking local/state mitigation action

O.5. Make (disaster assistance) Public Assistance contingent upon the community and state having an effective updated hazard mitigation plan and community participation in any available pre-disaster mitigation program for which hazards pose a significant threat in the plan .

O.6. For natural disasters in flood prone communities, make disaster assistance contingent upon NFIP participation, compliance, and maintenance of insurance for all structures in the SFHA.

O.7. Ensure that actions undertaken pursuant to emergency action plans do not cause adverse flood impacts on other properties in the community or other communities

O.8. Find ways to use local monitoring data in warning the public of impending disasters

O.10. Establish a combined review process for community/state compliance, mitigation, enforcement after a flood

M&ES Comments

O.11. Establish a comprehensive set of emergency rules for funding, cost-sharing, and priorities so federal programs after a disaster are consistent

O.12. Establish a uniform set of application forms for all federal post-disaster assistance for mitigation

O.13. Work with all federal agencies to ensure post-disaster policies and programs are consistent with NFIP and national resilience/sustainability goals

O.14. Review PA and IA and all federal agency post disaster programs for consistency with all relevant federal Executive Orders (especially floodplains, wetlands, resilience and climate change)

O.15. Ensure that PA staff and contractors have expertise to make decisions about post-disaster reconstruction of public infrastructure and facilities that incorporate mitigation

O.16. Revise Stafford Act provisions to allow reimbursement of overwhelmed communities for post- disaster damage assessments, substantial damage determination, ordinance administration, permitting up to 24 months after disaster

O. 17. Collect and share damage assessment under IA with State and local officials

O.18. Develop and utilize methods to track all federal expenditures and lost revenue due to each disaster declaration in order to determine the full cost to society and taxpayers of disasters. Publish preliminary results within one year of the declaration and final results within 5.

Q 19. Establish a federal oversight group similar to the National Transportation Safety Board, to collect data and analyze the damages, cause and economic, social and environmental impacts of all disasters

O.20. Require all federal recovery programs be reviewed and adjusted to consider mitigation and resiliency alternatives and evaluate long term solutions (require that water resource projects and PL 84- 99 for example consider non-structural measures )

O.21. FEMA, in consultation with other appropriate federal agencies, develop and maintain a national comprehensive strategic framework for mitigation and mitigation related metrics that are used to measure the success of a post-event disaster recovery. Require that mitigation metric be developed and used as an indicator of a of a successful disaster management and recovery

O. 22. Improve the efficiency and delivery of HMTAP such as allowing FCOs to approve requests in the field versus FEMA Regions or FEMA HQ.

O. 24. Assist in Building State Capability Including Mechanisms to Assist with Catastrophic and Multiple Events.

M&ES Comments

O. 25. Improve the Federal Government’s Ability to Supplement State Program’s Capability with Robust and Timely Technical Assistance in a Post-Disaster Environment.

O. 26. Require detailed tracking and enforcement of required flood insurance on Group Flood Insurance Policies and flood insurance on SBA Disaster Loans post-Flooding. Flood insurance should also be required on SBA Disaster Loans that are in NSFHAs.

P. Economic Methods and Policies P.1. Develop and transition to a National Economic resilience/Sustainability standard instead of National Economic Development standard for water resource projects

P.2. Evaluate how to implement National Research Council recommendations on B/C analysis

P.3. Revise B/C procedure to account for opportunity costs (foregone benefits)

P.4. Consider and broaden regulations governing FEMA’s B/C analysis to include all benefits including non-market societal and environmental benefits

P.5. Conduct a study to determine the advantages/disadvantages of a unified flood-only benefit/cost method for FEMA and the Corps

P.6. Utilize FEMA’s National Benefit/Cost Team to continuously evaluate the B/C method and procedures

P.7. Continue to develop and apply methods to quantify natural functions/resources Also see K.6

P.8. Enable and support federal interagency and interdepartmental water policy coordinating mechanisms to implement Principles, Requirements and Guidelines

P.9. Upgrade agency Guidelines to reflect the new Principles and Requirements to include sustainability; account for all benefits; provide greater emphasis on nonstructural; and to balance economic, social and environmental concerns

P.10. For nonstructural projects, include cost of land and easements as part of total project costs, not local sponsor shareP.11. Direct and fund a new evaluation of the use of risk-based analysis in the design and construction of flood risk reduction structures

P.12. Provide guidance for the use of risk-based analysis for projects in high-risk areas (urban levees)

P.15. Modify the Corps’ standard cost-sharing formula to provide a 75/25 federal/local ratio for all nonstructural projects Page 26 M&ES Comments

P. 16 Revise all cost sharing formulas to take into account the adequacy of the community’s floodplain management program using the CRS classification (or something) as a surrogate.

Q. Partnerships & Incentives Q.1. Provide incentives for the acceptance of responsibility for flood risk by citizens, states, communities, private sector Also see R.1–13; S1–15; T.1–12

Q.2. Amend Disaster Relief Act to apportion costs, responsibilities, roles among fed, state, locals, public commensurate with risk (sliding cost share as incentive)

Q.3. Create financial incentives for communities, such as: basing all federal flood-related assistance to states and localities on a sliding cost-share: the more mitigation, the smaller the non-federal share; nonstructural measures and those that retain/enhance natural systems should always get a larger federal share

Q.4. Make receipt of any federal disaster assistance (public or private) contingent upon taking mitigation measures and the purchase of insurance

Q.5. Make Public and individual Assistance and mitigation grant eligibility contingent on NFIP participation and compliance and on maintaining flood insurance

Q.6. Award increased Public Assistance to communities that meet all existing or future national standards for infrastructure

Q.7. Amend existing law so that communities would be allowed to bank mitigation expenditures as non- federal share of next disaster

Q.8. Make all flood related mitigation funding (including levee and dam funds) contingent on having a comprehensive, mitigation plan that will support community resilience/sustainability.

Q.9. Support and fund incentives for sustainable uses of floodprone agricultural lands

Q.10. Reduce subsidized crop insurance and crop disaster assistance (disincentives to wise use of floodprone lands) and tie all such taxpayer support to producer conservation compliance.

Q.11. Use incentives to encourage alternative, sustainable crops in flood prone areas

Q.12. Deny subsidized crop insurance and disaster payments to agricultural producers with repetitive losses who do not accept offers of permanent easements or switch to alternative crops

M&ES Comments

Q.13. States should Join together in existing or form new mutual aid (emergency management assistance) compacts

Q.14. Delegate (with monitoring) to qualified states the administration of flood mapping, HMGP, FMA, CAP, and environmental reviews for mitigation projects

Q.15. Explore use of true delegation model to move responsibility for NFIP activities to states (mapping, monitoring communities for compliance, technical assistance, training, etc.)

Q.16. Make CAP funding contingent upon the state’s provision of one fully funded professional full-time position—a CFM in floodplain management

Q. 17. Encourage market-driven private-sector incentives for mitigation

Q. 18. Federal agencies should encourage integration of certification programs for the International Codes and for floodplain management (CFM)

Q. 19. Deny subsidized assistance for public infrastructure that would encourage development in flood risk areas

Q.20. Prohibit the use of federal funds to build any infrastructure to serve currently undeveloped SFHA.

Q. 21.Reform the casualty loss deduction to better target the deduction as well as incentivize those that have mitigated. For example, limits could be set as to the number of times a person could claim the deduction without first mitigating as well as a means tested system to limit incomes of claimants.

Q. 22. Develop a hazard mitigation tax credit much like energy efficiency tax credits that are given to property owners.

Q. 23. Allow for tax advantaged disaster savings accounts

Q. 24. Provide specific IRS guidance more broadly exempting cost effective mitigation assistance from and funding source from federal taxes. Currently only FEMA mitigation programs have a specific exemption.

R. Federal Leadership R.1. Establish high-level coordinating mechanism for federal water resources policy

R.2. Establish a National Flood Risk Management Policy

M&ES Comments

R.3. Adopt a watershed-based, comprehensive approach for all federal water resources activities and programs

R.4. Evaluate compliance with federal EO on floodplain management to ensure 500-year protection for critical facilities; ensuring access to and fully operational facilities during 500-year flood; avoiding floodplain when possible; using future conditions in decision-making; avoiding adverse impacts

R.5. Assign responsibility for oversight of EO 11988 compliance to somewhere in Administration

R.6. Require all federal agencies to issue new floodplain management EO guidance that reflects other EO’s on resilience, sustainability and climate change, with stronger mechanisms for monitoring, reporting, enforcement and accountability; (example; Require that all Federally funded transportation projects incorporate comprehensive flood and storm hazard mitigation design standards.

R.7. Enforce all lease restrictions on federally leased floodprone land, especially denial of flood insurance, and non-renewal after expiration of the lease.

R.8. FEMA should Establish a work group to assess and implement recommendations of 2012 report on “Rethinking the NFIP”

R.9. ASFPM should analyze “Effective State Programs” to work with states to encourage states to move beyond basic and toward model flood risk management programs

R.10. Provide full funding for flood risk management data gathering and development (GIS, streamgaging, forecasting, mapping, Integrated Ocean Observing System, research)

R.11. Give FEMA Director discretionary authority (with input from localities and the state) to require communities to use advisory maps and BFEs (It could be a requirement of CRS communities to use advisory or preliminary maps as best available data.)

R.12. Support professional certification programs for floodplain managers, adjusters, agents, and others; provide more insurance-related training via the NFIP Training Contractor.

R.13. Provide generous sufficient and reliable funding for federal programs that generate the most long- term impact, i.e., technical assistance and state/local capability-buildings

R. 14. Make NFIP participation and disaster assistance contingent upon states’ ensuring that their funding, regulations, and programs comply with the NFIP; with monitoring and penalties for noncompliance

R. 15. Provide adequate resources and opportunities for collaboration with state and local partners of interagency coordination entities such as the Federal Interagency Floodplain Management Task Force and MITigation Federal Leadership Group (MitFLG).

M&ES Comments

R. 16. Consider shifting to a national model that delegates floodplain management authority to states, with incentives provided through ALL federal grants, disaster relief, etc.

R. 17. Support examinations of alternative paradigms for national flood policy and programs, including governance, mapping, avoidance of flood risk areas and flood insurance

R. 18. Provide incentives to encourage states to issue and enforce effective executive orders on floodplain management

R.19. Establish strong federal floodplain management rules for federal investments and actions that are based on the principles of long term resiliency – including from climate change, use of natural ecosystems for resilience/sustainability and flood damage reduction.

R. 20. Develop sustained state and local flood hazard mitigation grant programs that can complement federal investments in hazard mitigation.

R. 21. Provide incentives (CRS, disaster relief and others) for all state and local managers to be CFMs.

R. 22. Pass sufficient enabling authority for regions and communities to develop stormwater utilities or similar mechanisms that can provide resources for an array of flood risk management and loss reduction actions.

R. 23. FEMA should develop and implement a CAP-SSSE type program to assist states in building state hazard mitigation capability.

S. Building State & Local Capability S.1. Support and provide incentives to states in efforts to encourage progressive state and local programs and activities, including NAI approaches (explore allowing states to participate in the CRS program)

S.2. Develop procedures and implement the “managing state” concept

S.3. Increase funding for federal programs that provide technical expertise that supports state mitigation strategies and the production of mitigation grant applications

S.4. Encourage (or require as condition of CAP or grants) states and localities to conduct own engineering reviews, LOMR and LOMA submissions, and integrate state dam and levee safety programs with floodplain management Also see A.14

M&ES Comments

S.5. Redesign CAP and other delegation programs to emphasize building state and local capability instead of simply buying state services

S. 6. Negotiate CAP participation individually with each state with each change of state administration, and require governor-level commitment from state, using many forms of federal funding as an incentive

S.7. Same as above—change to: States need to upgrade their entire programs: regulations, intra- agency coordination, policies on where state emergency management funds are spent, their mitigation efforts, etc. There should be some minimum standards for state programs, which ASFPM should work with states/feds to create and promote.

S.8. Allow states to allocate up to 50% of CAP funding to state-selected non NFIP, but effective flood loss reduction activities (not projects)

S.9. Tie CAP funding to NFIP and flood disaster reduction-related needs and add annual inflation- indexed increases

S.10. Provide incentives and disincentives to encourage states to view CAP as auxiliary funding to state floodplain management programs, not sole source Require one full time state funded position (CFM) to receive any CAP funds.

S.11. Properly Adequately fund CRS verification program to ensure CRS credits are properly earned or class rating reduced.

S.12. No – the community is rewarded with reduced premiums and less flood risk

S.13. Publicize successful activities of CRS communities – why they are successful, how the activity reduces risk and/or promotes sustainability and how they got it all done

S.14. Develop, fund, and implement technical and financial support and other incentives for localities to conduct its own management and mitigation programs

S.15. Provide incentives to encourage communities to integrate floodplain management with land use and watershed conservation plans Require in HM Plans and for credit of flood plans in CRS.

S.16. Conduct independent reviews of state and local programs to determine effectiveness on a five year cycle.

S.1!7 All FEMA Regions should annually host meeting/training with State NFIP coordinators and SHMOs

M&ES Comments

T. Individual Accountability T.1. Continue to move to actuarially sound flood insurance rates over time for all buildings

T.2. Continue movement towards actuarial rates for pre-FIRM residences as per HFIAA; put them on the same path as others if they have a loss

T.3. Continue increasing insurance rates on repetitive loss structures; and move to full actuarial rates if SRL owners refuse an offer of mitigation assistance

T.4. (a) Encourage private insurance programs if the flood mapping, management and mitigation aspects can be accounted for

Encourage insurance and reinsurance industry to rate flood coverage as part of homeowners policies, with incentives for appropriate mitigation actions

T.5. Base receipt and amount of disaster assistance to individuals on the extent to which they mitigated and/or insured their flood risk

T.6. Establish procedure by which FEMA Director can require mitigation for a structure that has filed a flood damage claim

T.7. Give preference for mitigation grants to individuals who use their flood insurance claim payment for mitigation

T.8. Discontinue practice of waiving the flood insurance requirement after issuance of LOMR-Fs and LOMAs; apply risk-based rates instead. Also see F.5, G.2, K.13

T.8 (b) Deny disaster assistance to any structure for which a LOMA has been issued.

T.9. Expand outreach to the public, adjusters, and insurance agents about repetitive losses and how ICC can be a most effective tool to mitigate the flood risk and reduce insurance premiums

T.10. Appropriate additional funding for public outreach on flood risk and insurance, especially for communities with levees

T.11. Clearly communicate flood risk (e.g. policy renewal should show what actuarial rate would be as well as current rate); uncertainty in forecasts, better terminology; awareness campaigns

T.12 Enhance the outreach capabilities of FEA FEMA disaster, mitigation, insurance and mapping programs to promote a better understanding of individual risk and options to deal with the risk.

T.13. Ensure actual cost of flood insurance is annually communicated clearly and directly to policy holders, regardless of discounts or subsidies

M&ES Comments

U. Agriculture Policies U.1. Evaluate federal agricultural policies and their impact on flood loss reduction and floodplain function and resources; then use this data to integrate federal agencies flood risk programs into other programs (FIFM-TF or MitFLG)

U.2. Increase funding for popular and effective agricultural conservation programs that protect natural values of floodprone lands, floodplain functions and natural ecosystem resources

U.3. Integrate agriculture programs with flood loss reduction and floodplain management programs

U.4. Tie the Conservation Reserve Program and related agricultural programs to market prices of commodities Also see Q.9, Q.10, Q.11, Q.12; I.14; K.13

V. Climate Change V.1. Evaluate regional/local vulnerability of U.S. population centers to climate change impacts and provide adaptation options

V.1.a Develop unified national policy/response plan to deal with the impacts of climate change, especially sea level rise, including mitigation prior to an event and response after an event. Develop minimum standards for the expenditure of all federal dollars following a disaster to account for anticipated climate impacts..

V.2. Support/participate in data collection & analysis on impacts of and adaptation to climate change

V.3. Require analysis of impacts & adaptations to climate in all mitigation planning.

V.4. Issue Executive Order to compel federal agency consideration of climate change impacts Also see L.3

V.5. Revise federal agencies BCA methods to include projected impacts of climate change over the life of the project.

V.6. Develop grant guidance to encourage/incentivize projects to address climate change

V.7. Require all Class 7 and better CRS communities to consider and plan for climate change in their floodplain management plans, maps and regulations.

M&ES Comments

V.8 Require all Class 4 and better CRS communities to include the impacts of land use and climate changes through 2100 in their mapping, planning, and regulations.

W. Beach Nourishment W.1. Develop guidance to determine when beach renourishment is in the federal interest

W.2. Do not use beach nourishment in any federally funded projects, unless federal interest will be met

W.3: Require that the Federal interest in beach nourishment be demonstrated to exceed the Federal interest in other, more permanent mitigation options that are more sustainable and don’t require ongoing expenditures. At least reduce the federal cost share for beach nourishment

W.4: Require that benefit-cost analyses for Federally funded nourishment projects identify and evaluate full costs, including periodic renourishment, increased costs for locating and acquiring suitable material, long-term project maintenance and required protection of induced development and redevelopment.

W.5: Revise the cost-sharing agreements for Federal nourishment projects to shift more of the cost to non-Federal sponsors who receive the majority of the project benefits (suggest 35% Federal – 65% non- Federal as a start).

W.6: Require that Federal nourishment projects be monitored and evaluated periodically to determine if the project has actually performed as planned and justified based on costs, to determine if the project should be abandoned or the design should be amended to reflect changing conditions, and to increase efficiencies, reduce costs and provide greater benefits.

W.7: Include specific requirements (not guidance) for public access to and use of beaches nourished with Federal dollars as a condition of funding, including minimum number of access points, parking and rest rooms that provide “meaningful” public access.

W.8: Require that planning, benefit-cost analyses, design and construction of Federal nourishment projects account for sea level rise.

W.9: Require benefit cost analyses for Federal nourishment projects to consider all mitigation alternatives, including acquisition and land use management options, and to demonstrate that these options are not cost-beneficial before considering nourishment.

M&ES Comments

X. Resilience NOTE: this is a suggested added area of policy. Feel free to suggest national flood policy that relates to this. In the final document, we will likely pull items from the remainder of the list that may fit more appropriately in the resilience category and move them here.

M&ES Comments

ASFPM draft national flood policy