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 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. Do not use 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 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 Can subsidence and erosion in particular be calculated in a linear fashion that can be projected in this fashion for 150 years? It would seem that the changes in soils and land uses over time could create significant shifts in these impacts as would manmade interventions to stabilize coastal or riverine areas to stop erosion. Aren’t the current maps based on storm surge scenarios?

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

A.5. Map and designate properties with repeat flood damage claims and adjacent areas with repeat flooding histories (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

This would be very helpful for jurisdictions with large forced drainage systems that have repetitive flooding. At this time, the floodplain manager must develop a height for elevation of severe repetitive loss structures or substantially damaged structures required to elevate outside the SFHA.

I am not sure about the increased cost for claims as that encourages people to avoid claims (as preferred risk insureds have told me) and therefore 1) defer repairs or maintenance, and 2) misrepresent the flood risk to the structure and area.

ASFPM draft national flood policyPage 1

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

Any suggestions regarding “repetitive loss” should carry a definition that specifies whether these are for new definition (substantially damaged) or the old definition pre-BW-12 of two floods with claims over $1,000.

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 I do not know what options there might be or why one might want to divorce the best available data (many would argue flood maps) with a presumably less scientific approach.

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

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).

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 , coastal or riverine erosion, channel migration, etc. (as part of the 100 year standard) This is interesting. Maybe this could be interpreted as an eligible activity under PDM planning grants? Communities will need funding to develop the research that would underpin these layers. Maybe this would be eligible for funding under the Continuing Training Grants for Rural Planning.

A.11. (a) 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 We support the availability of Coastal A Zone determinations from FEMA during the mapping process, but not necessarily the inclusion of the Coastal A Zone into the V zone definition. There are different mitigation options based on the different level of risk, and we would prefer to keep the flexibility to apply higher standards at the local level than to have these two different risk levels combined streamlining the limitations on funding and development techniques.

At this time, CRS is offering incentives for regulating the Coastal A Zone like the V, while the mapping side of the house refuses to provide the LiMWA. Our parish funded this effort independently and will move forward with it if the governing body agrees to adopt it, but FEMA has all the data and could run it in a more consistent and efficient manner. (A.21 covers this without ambiguity).

ASFPM draft national flood policyPage 2

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

A.11 (b) 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 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) Provide FEMA the authorization to dDelegate authority and funding for mapping of all coastal and riverine hazards on NFIP flood maps to qualified states under the Cooperating Technical Partners program. (Should also require those states that are so authorized to undertake the mapping in accordance with standards that equal or exceed FEMA’s standards.) .

Ignoring for the moment the constitutional status of states v. local or county governments, does this have to be a FEMA/State delegation? Some local jurisdictions have better information and different political priorities than the state and may be better able to achieve optimal goals. Los Angeles County is bigger than some states by land and population, for example. Understanding the value of developing maps based on watersheds that can cross jurisdictional boundaries, states are as prone to these limitations as local communities. I would not always jump to the state as the smallest level of partnering agency.

A.12. (b) Require CTP delegated states to develop and maintain an archival system for all flood map models for data stewardship and storage. 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. 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 to qualified states and state designated local authorities, with local review/sign off as needed Also see S.4 The local authority should always need to be in agreement with the change required (and I believe that the process now requires this). The local authority will be committed to enforcing NFIP regulations based on the maps and is responsible for the health and safety of the community. The qualifications at the state level would have to include a working professional floodplain management staff with working knowledge of the conditions represented in the LOMR.

ASFPM draft national flood policyPage 3

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

A.15. Produce all flood maps in geospatial data format & allow all such data as a substitute for traditional paper products ;

A. 15 (A) require LOMRs to be in the same geospatial format, including updated databases As far as I know, this is happening now.

EMA should be incorporating LOMRs into the panels by simply changing the databaee. There is no reason for publishing paper LOMRs any longer.

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 The use of the old maps needs some attention as well. Insurance companies have been refusing to use the maps prior to the first FIRMs though they were the best available data at the time and relied upon by NFIP communities prior to the availability of the FIRMs. Flood boundary maps were the best available data at the time, but are not being consistently recognized as acceptable to show compliant building. More structures are therefore found to be minus rated than if these maps were recognized as a sufficient basis for regulatory decision making.

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 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

This is a very expensive and often unnecessary option. This should only be done where scientifically justified, and that is not very often. More important would be to change the allowable increase to 0.01’ and continue to use traditional analytical methods.

A.21. LiMWAs should not be optional and should be used 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. a. An [informational] layer should be provided to all communities downstream of a dam showing the SFHA assuming the dam is removed.

A.23(b) An (informational) layer should be provided to all communities downstream of a dam showing the SFHA assuming the dam fails during the 1% chance flood.

ASFPM draft national flood policyPage 4

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

A.24. Produce future conditions mapping that includes all scientific and planned projections of sea level rise, increase in riverine rainfall, watershed changes, etc. Combine with A16 to include changes in flooding due to increased snow melt etc. Considering recent Colorado flooding, deforestation should be considered as well whether through disaster or decisions regarding timber harvest (the new term for clearcutting).

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.

A,26(a) Required participating communities to provide update corporate boundaries within 6-months of any annexation or change. (Since that is already a requirement in the CFR, maybe the recommendation should be a fine of $1,000/day for every day the change isn’t reported.)

A.26.(b) Require FEMA to publish a LOMR displaying the boundary change under (a) within 60 days.

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 communities to adopt those maps for administering the NFIP requirements in their community

B.2. Automate data inputs and update 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.

ASFPM draft national flood policyPage 5

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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

This needs to include specifics such as:

1) purchasing flowage easements

2) buying flood insurance for affected properties

3) purchasing and relocating affected buildings

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

B.6. (a) Develop engineering models that are properly calibrated to historic flood events 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 that engineering models are open source, public, user-friendly, and widely accepted

B.8. Calculations of flood flow frequencies should be determined based upon a 95% confidence level to reduce the uncertainty in associated flows used for flood risk determinations.

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 foster holistic and no adverse impact stormwater 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 also the potential for increased risk due to land use changes and climate change by quantifying watershed and stormwater runoff that affects the site. Don’t we already look at pre and post stormwater runoff as a practice for all permitted activities in the floodplain? Is this to assess risk outside the floodplain? Including climate change here if it is not already folded into the mapping process seems wise. The rest would seem to be in place.

ASFPM draft national flood policyPage 6

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

C.4. Encourage/incentivize (CRS and other) rainfall and runoff infiltration, low impact development and green infrastructure techniques to reduce and manage flood flows and runoff, water quantity and water quality. I would like to see more explicit focus on infiltration and permeable surfaces rather than a focus on moving water away from the land via conveyance. Good direction that already has some traction.

C.5 Apply and expand NFIP Community Rating concept to allow EPA and FEMA to credit community actions to reduce stormwater flooding risk and to improve water quality and green 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 via control of not only peak flows, but also the volume of runoff. Already incentives in CRS. (look up prior to submission )

C.7. Wetlands and other storage areas outside of the SFHA should be preserved to prevent downstream increases in flood frequency and heights. This is the type of activity that could be awarded CRS points in multijurisdictional plans. Recognizing the interdependence of the jurisdictions and protecting the assets of the upstream community for the benefit of the downstream. This will also outline the potential liability for changes that might damage downstream investments or assets.

C.8. EPA, as part of MS4 permits should require the control of the peak and volume of runoff to the 1% event, or greater, greater than the 2-10 year events to prevent the erosion of stream channels, pollution, and damage to adjoining structures which creates more pollution. Is there data that suggests that the recurrence of 25 year storms is such that it should be the design minimum rather than 2 or 10? Should the standard be different based on the rainfall history and projections for the geographical area?

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. Streams should have a required setback regardless of the area adjacent being natural or not. The stream is a natural environment and the riparian habitat and environmental services should not be disturbed or eliminated for the benefit of the adjacent activity. Often we see grading right to the apex of the bank and the subsequent failure of the previously stable bank.

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 mitigate their impact. There may be some thoughtful and valuable disagreement about the value of certain LID techniques and their value to habitat or flood risk, energy use, land use, etc., so I don’t know that I would feel comfortable supporting this suggestion.

ASFPM draft national flood policyPage 7

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

D. Water Quality

See C. Stormwater Management

E. Data & Technology

1. From Mitigation Committee Respondant: I suggest that the “Open Source” should not be a requirement to hydraulic/hydrologic models used for flooding studies since it does not necessarily add value to the performance of flooding studies.

2. Presently, none of the most used models are open source and that does not diminish its capabilities for accurate flood simulations. For Instance, HEC-RAS is not open source The Corps distribution policy indicates: that “USACE does not distribute the code Computer Source Code: CEIWR-HEC generally discourages the distribution of CEIWR-HEC source code. The source code is usually only required when porting a program to a different computer or to modify it. If appropriate and available, CEWIR-HEC will provide the source for these purposes. However, CEIWR-HEC cannot provide assistance with the code. Source code for components under development will not be distributed. During development, some routines will be changing frequently. The proliferation of code, that is rapidly becoming out-of-date, is not in the public interest. CEIWR-HEC will make the determination of when the source code is sufficiently stable on a case-by-case basis.” http://www.hec.usace.army.mil/software/distribution_policy.aspx)

3. In my opinion,  restricting flood modeling to public models would hamper innovation and fair competition that helps to improve software tools. The best 2D models available are not in the public domain. Many private software developers worldwide invest enormous efforts and money to produce state-of-the art models. As an analogy, most software using in the generation of maps including Operating Systems, CAD, GIS and other systems that are not open source. Nonetheless they offer quality tools for Floodplain Managers. Selecting the most appropriate software for each task should be left to the experts, provided that the software passes adequate testing procedures. 

4. ASFPM should promote the establishment of standardized test that any model should pass in order to be used for flooding studies. Other developed countries have made significant advances in this direction. For instance the UK Environmental Agency has prepared 2D model benchmark tests that allow evaluation which hydraulic modelling packages are suitable for which types of flood risk management modelling applications. In thie way government agencies and consultants can apply available flood modelling tools with confidence. It also promotes continuous improvement in the flood model developer community and has helped to raise modelling capabilities and standards.

5. FEMA announced last year at the FMA conference in Anaheim that the Agency was going to eliminate the list of Approved models or “Numerical Models Meeting the Minimum Requirement of NFIP” and give more flexibility to

ASFPM draft national flood policyPage 8

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

choose newer and more advanced models. The idea was to give the responsibility to the local or national agency doing a flood analysis to verify the models used to evaluate the flood hazard adhere to 44 CFR 65.6 a(6). ASFPM should encourage this effort so that it becomes stablished.

E.1. Provide reliable funds for stream gauging and identify additional funding sources for streamflow data gathering and analysis. 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 stream gauges.” In the interim, OEP managers should be partners with the floodplain managers as they may have access to stream gage funding that is from many sources.

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

E.3. Develop mechanisms by which NWS/local warning systems can supplement stream gage data

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.

There has been a shift in some states to greater availability of this data to jurisdictions and by extension their agents for better research and planning. Considering the push to move NFIP to community-based and private institution provision, the availability of this data could be decreasing, not increasing, if we don’t push for reporting of all flood activity to the NFIP regardless of the point of sale and claims payment. Data collected by the Parish through observation (not collection of data for a federally funded grant application) or submission for permits is arguably already in the public domain, and should remain so. I do not know if the fight to make flood data available to the public will increase our access to data significantly.

This would violate the Privacy Act. Rather than asking FEMA to violate a federal law we should seek the exemption of this data from the Privacy Act, but that is highly unlikely.

ASFPM draft national flood policyPage 9

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

State NFIP Coordinators and SHMOs have access to this information and can release jurisdiction-specific data to local governments withholding owner name and ss#. Proactive states and local governments use the information. Otherwise, the “public” isn’t going to understand it, use it, or benefit from it. I suggest deleting from Section E. D. Mills.

E.5. Develop open-source tools for post-flood damage estimation. This may belong in Section H because it directly relates to HMGP Policy memos as well as data development specific to the BCA modules. The rest of E is mostly flood hazard mapping/assessment related.

E.6. (a)Collect nationwide data on 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.

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

ASFPM draft national flood policy Page 10

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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 thaen current estimates.

F. Development Standards, Regulations and Codes

One major challenge that is not included here, and may not be known to some partners, are the limitations put on mitigation by some communities. Just as some communities don’t allow clothes drying outside or solar panels (placing unnecessary demand on the electric system) there are other communities that are trying to protect the existing investments by capping the height that new structures can be raised or built. Flood insurance should not be discounted in neighborhoods or jurisdictions that have these restrictions that limit freeboard or even elevations that meet new flood maps.

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 As a jurisdiction trying to reduce risk daily, I am prone to dislike the top down requirements that are broad and don’t give us the opportunity to choose the tactics that are achievable in our communities. We are working on adopting stricter standards and are always seeking better information. There is already a set of basic requirements. If the goal is to push the availability of other lood insurance carriers, this may or may not move that forward as communities push back against their floodplain managers and look for other options. Our residents have already proposed that the jurisdiction 1316 at least the V zone and let people take their chances if they want. The lure of savings is not sufficient to keep the program active when the increases in premiums constantly exceed the savings gained. Therefore, the program needs to remain accessible for entry and retain a balance between the carrot of lower insurance rates and the stick of no insurance at all.

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

ASFPM draft national flood policy Page 11

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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 . Require, or provide either incentives or less coverage in these areas?

F.4. Revise NFIP regulations 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 These should be supported with studies, and ASFPM should work with the national realtors and appraisal associations to ensure that there is monetized value in the freeboard element of safety. At this point, our builders have pointed out (which has been borne out in the appraisals that we see) that neither flood risk, damage, or safety are taken into account when a structure has been repaired. These should be represented as a value or demerit, which would further encourage safe building.

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

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

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 500-year level with freeboard and estimated future conditions incorporated, require 500-year protection with access and operability during the 500 year event, and set other standards as needed Also see J.1–7 I am not sure where this is coming from exactly. We need to have fire stations near the coast to meet regulations for being within a certain timeframe from structures. It is infeasible to have the trucks lifted, but we are lucky that we are rarely if ever subject to flash floods (the vehicles are removed prior to storms). We seek to elevate the offices and living quarters. I think that at least as much attention should be given to wet floodproofing as always falling back to freeboard. Local governments, given access to information about the performance of similar facilities should be able to decide what level of safety is on balance the best for the community. If, as already happens with PA assistance, the jurisdiction is considered underinsured, maybe the parish wouldn’t get the same insurance payment. Maybe the fire department doesn’t need to work from that facility during or immediately after the storm. One solution does not fit all.

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

ASFPM draft national flood policy Page 12

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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-year flood data (and recommended floodway analyses) Explore alignment of thresholds with requirements of the CWA. The threshold should be two or more structures and 1 acre or more.

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. So, subdivisions in the SFHA need to already be at the BFE? My house, right now, is only above the new DFIRM due to the slab and 6 inches step up into the house. This type of regulations is going to put significant pressure on the FEMA mapping effort or by communities to find or provide LOMRs for land that can be built on. Again, our residents are already accusing the jurisdiction of angling to not allow building in the coastal areas. To also not allow building in what is our higher ground, but not above the BFE, would further the appearance that this is indeed our agenda.

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).. Is there a middle ground here for a 25 year event? As importantly, is there data in the ASFPM intellectual bank to show what the cost differential for builders is between different storms? My jurisdiction already requires a 25 year storm for the model, but the general public (who lives in subdivisions that flood despite the regulations) wanted to see 50 or 100 years as the design model. The building community came out against the measure demanding that we provide the cost of the additional expenditures, and a benefit cost analysis supporting the adoption of such efforts. We did not, and do not have, that information, and the elected officials are not looking like they will move forward without the answers to those questions.

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).

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.

ASFPM draft national flood policy Page 13

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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 Again, big supporter of the Coastal A Zone, working on getting that adopted. This is another situation where some local studies or benchmarks on the cost of elevation with or without fill would be great. There are some great national academy studies, but those are not accepted by the industry as applicable.

F.13. Revise NFIP regulations to prohibit septic systems in A or V zones Is this an attempt to get infrastructure extended into the V zone? Coastal communities already have water in the coastal areas. Sewerage could be next if a significant loss of buildable land is the point o the proposal.

F.14.(a) 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.15. Revise the NFIP regulations to require local ordinance to require local floodplain administrator to define they are responsible to determine substantial damage. Not against this in principle, and this is the practice in our jurisdiction, but is this practical for all communities? The assessor and permits office often has the data needed to make this determination. Many floodplain managers are also engineers, building officials, mitigation officers, etc. This may be an area for a required outreach or education regarding the office required to make the determination. The guidance could favor education on this topic as it does other topics in the 300 series.

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 (so FEMA quits approving islands in the middle of the

floodplain) Adequate protection against erosion etc.

F.15. Revise the NFIP regulations to require local ordinance to require local floodplain administrator or building official to define 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

ASFPM draft national flood policy Page 14

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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

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. Amen. This message needs to be adopted by FEMA as well.

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.

I support buffer zones around streams and any waterway that feeds into a stream or other waterbody. If this is similar, I am supportive as long as this is sensitive to both the amount of land available and the creative practices that can stabilize shorelines and provide habitat and storm protection.

F.19 Revise the LOMC requirements to require an Environmental Assessment in all instances to ensure endangered species are not impacted. I disagree – this recommendation should be deleted in its entirety. It may be appropriate for LOMR-Fs, but no other LOMR, and certainly not for LOMAs.

F. 20 Establish NFIP regulations to ensure Endangered Species Act (ESA) compliance with development, LOMR-FC’s 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. Flexibility is required in this instance as well. Our Coastal A Zone has some areas that would need lifts four feet or less above ground. In areas with low wave action these are allowed to be built on a chain wall, which is an improvement on slabs or fill, and the right direction without being overly proscriptive.

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)

G.2. Discontinue practice of waiving the flood insurance requirement after issuance of LOMRs and , 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 –

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

ASFPM draft national flood policy Page 15

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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.

FEMA can’t even map all the floodplains or update maps that were created 40 years ago. And, the insurance industry is already doing a lousy job of even making sure the policy is associated with the correct CID. Making the maps more complicated will do more harm than good.

G.7. Apply mandatory purchase requirement to non-federally regulated mortgages or require that le Just do away with IA. If you don’t have flood insurance, and you get flooded, your screwed. After almost 50 years it’s time to shut off the money spicket. nder 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 For structures (residential or non-residential) disaster assistance should only be available once. If the building is flooded a second time, and it isn’t insured, too bad.

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

ASFPM draft national flood policy Page 16

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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 C And, where FEMA undermines CRS communities by approving inappropriate LOMRs, assess penalties against the FEMA staff.RS community or not, at a cost of over $200 million per year.

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. This sounds great, but is fraught with the practical realization that political influence that would lead to failure.

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. The only way to reduce PA is direct new development and substantial improvements to areas outside the SFHA. PA and IA are the “gifts” that keeps on giving for pols.

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.

ASFPM draft national flood policy Page 17

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

G.23 (a) 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.

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. Encourage states and communities through incentives 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.2. Expand ICC to allow assignment of claim to fully cover the acquisition costs of severely damaged and destroyed buildings as a means of compliance.

H.3. 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 for necessary geographies to reflect market mitigation costs that requires match funding or other mechanisms that ensure cost control.

H.4. Establish permanent authorization for US Army Corps of Engineers to conduct nonstructural floodproofing projects; increase funding for existing Corps nonstructural programs .

ASFPM draft national flood policy Page 18

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

H.5.Streamline and institutionalize methods for delivering mitigation assistance and funding after flood disasters through development of a mitigation options tool which can be delivered to impacted property owners to lay out mitigation options (and financial impacts) . Such a tool would inform mitigation decision and HMA grant participation. It needs to include real-time insurance benefits, IAHP grants, and EHP issues so that owners are provided. This conversation can’t be complete without a discussion about having timely information about insurance benefits for the determinations of substantial damage, permit needs, and to give the owners the best variety of opportunities for mitigation appropriate to their situation.

H. 6. (a)Train FCOs, PA and IA field staff to require post-disaster mitigation and incorporate into all-hazards mitigation plans and post-disaster response and recovery programs.

H. 6. (b) Ensure that PA staff and contractors have expertise to make decisions about post-disaster reconstruction of public infrastructure and facilities that incorporate mitigation through complete application of all work eligible through Stafford Act Section 406 Public Assistance Hazard Mitigation. Measure accomplishments through defined metrics using reportable tools to demonstrate that every PA Public Worksheet has been fully evaluated for eligible mitigation opportunities.

H.6. (c) Develop necessary training and tools to ensure full use of Public Assistance 406 Mitigation Program to repair/replace damaged public infrastructure in a more resilient manner.

H.7. Continue to advocate for HMGP base funding at 15% of eligible federal disaster recovery costs; with 20% HMGP funding for states with FEMA approved enhanced mitigation plans.

H.8. Continue to work to maintain accurate, current RL and SRL property lists depicting property status allowing states and local governments to target mitigation programs to these properties.

H.9. Fully expand the state management oversight pilot policy program to all eligible states for administrative oversight of HMGP, FMA, and PDM.

H.10.(a). Periodically (3-5 years) conduct an independent evaluation of mitigation programs including PDM, HMGP and FMA to quantify their effectiveness in reducing losses.

H.10.(b) Expand FEMA’s Building Sciences post-disaster Materials Assessment Teams work to more disasters from multiple hazards to increase knowledge of mitigation performance measures so that a more comprehensive evaluation of building code and materials performance is evaluated nationwide.

H.11. Evaluate mitigation plans of communities hit by a disaster and summarize lessons learned and evaluate effectiveness of mitigation plans.

H.12. Encourage state and local mitigation plans to incorporate consideration of cost-effective infrastructure mitigation investments to increase community resiliency.

H.13. Cross-train code officials and floodplain managers in building code-flood loss reduction programs.

ASFPM draft national flood policy Page 19

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

H.14. Build state capability for mitigation by developing a FEMA/State partnership program for mitigation modeled on the CAP.

H.15. Firmly clarify and define eligibility for “structural/non-structural” or “major/minor” flood control projects using FEMA HMA grant programs to ensure that traditional “non-structural” projects are funded in lieu of structural projects eligible for US Army Corps of Engineers or USDA Natural Resource Conservation Service funds.

H.16.Promote dissemination of success stories (such as those on FEMA.gov); emphasize mitigation effects on flood insurance premiums.

H.17. Increase emphasis in state and local mitigation plans to state and local capabilities/programs and what they can and will do, without federal funding.

H.18. Require a high-level federal interagency (MitFLG?) follow-up review of causes, costs, impacts, policies, and mitigation response for all major Presidentially-declared disasters. This can be included in the JFO Hot Wash process at JFO closing or disaster programs close out.

H.19. Advocate for steady HUD, USDA, SBA and other mitigation funding through Stafford Act amendments. This could prevent uneven federal financial disaster recovery support due to sequestration or lack of will to fund programs such as Community Development Block Grant – DR or USDA Emergency Watershed Protection Programs. The full suite of federally-declared disaster recovery funding programs should consistently available nationwide.

H.20. Allow the insured to purchase additional $30,000 blocks of ICC coverage, over and above the standard $30,000 that is included in the SFP, to a limit of $150,000 worth of Increased Cost of Compliance (ICC).

H.21. For compliance reasons, allow ICC funds to be accessed by an insured ___ whose structure has been remapped from an A zone into a Coastal A or V zone.

H.22 Encourage market-driven private-sector incentives for mitigation.

H.23. Develop open-source tools for post-flood damage estimation to better inform post-disaster mitigation strategies for program/technical assistance/grant targeting, BCA support data, and review and improvement of local risk reduction policies.

H.24. Develop sustained state and local flood hazard mitigation grant programs that can complement federal investments in hazard mitigation.

H.25. Evaluate how to implement National Research Council recommendations on benefit-cost analysis into FEMA’s BCA Tool.

H. 26. Consider and broaden regulations governing FEMA’s BCA policies to include all benefits including non-market societal and environmental benefits.

ASFPM draft national flood policy Page 20

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

H. 27. . Conduct a study to determine the advantages/disadvantages of developing unified cost effectiveness policies and procedures for FEMA and the USACE for flood mitigation projects. .

H. 29. Continue to develop and apply methods to quantify natural functions/resources Also see K.6.

I. Structural Projects

I.1. (a) Use structural flood control projects only as a last mitigation resort & never to protect undeveloped or added value development to “protected” land. Delete. This may not be appropriate for all areas. Communities may need to construct ‘structural flood control projects’ in an undeveloped area as an enticement for development and the solution could be beneficial in other ways instead of just environmentally. The project could be part of a bigger plan envisioned by the community. These kinds of requirements can’t come at the national level.

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. Delete. Again, this is a major requirement and shouldn’t be made at the national level. This could be a huge burden for some communities.

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 Delete ‘estimated future’ conditions. These would be based on numerous things that could easily, and in most cases, change. Requiring structures to be built to ‘future’ conditions proves many times to be a waste of future tax payer dollars.

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

ASFPM draft national flood policy Page 21

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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 alternatives analysis prior to funding structural projects.

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) Suggest 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

I.12. Develop an efficient method for local officials to inspect, maintain and repair or remove flood control structures using a nationally consistent data tool.

I.13. Create national specifications for levees (and other structures) definitions that incorporate consideration of function, risk, and vulnerability

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.

ASFPM draft national flood policy Page 22

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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

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 (a) Include requirements that Corps projects meet the same wetlands mitigation standards as other agencies

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.

ASFPM draft national flood policy Page 23

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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

I. 31. Require communities 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

The maps of areas “protected” by levees need to be some sort of “A-zone” so that the lands are regulated (elevation required) and flood insurance is mandatory.

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 rise, etc. during the infrastructure’s expected life; these standards become a condition of federal funding

J.2. Develop FEMA Public Assistance Program 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.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

ASFPM draft national flood policy Page 24

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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 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

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 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 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 for CRS class 4 and 1 communities.

L. Coastal Issues

ASFPM draft national flood policy Page 25

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

L.1. Share/redirect navigation fuel tax for coastal and aquatic habitat restoration As minimum requirement, jurisdiction must have on the books and enforced a provision that any new permit for creation of a waterway or road to support resource exploration must be mitigated (filled in and repopulated/stabilized with endemic species).

Permitted resource mining activities must pay independent entity to track the subsidence during the extraction period and mitigate the loss of flood risk protection lost due to that subsidence.

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.

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 See notes for A3. What would this look like? In the past 100 years we have lost vast coastal land, cypress forests, marshes and wetlands. Is this policy suggesting that we only build coastal restoration projects for areas that will not be open water in 100 years assuming this same or more accelerated rate?

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. Great idea. I understand that one hard armoring project 1/3 washed away in the next storm. Since it was a mitigation project already (which arguably failed) no PA or mitigation funds could be had to complete it. That being said, if armoring was required for some temporary timeframe to protect plantings until they could root and stabilize the soils behind the armoring, the armoring analysis should take into consideration the second phase.

L.5. Enforce the protection of dunes and mangroves as required in NFIP regulations We who are new at having a climate to support mangroves could benefit from discussion with historical mangrove communities about the environmental needs of mangroves/buffer zones, soils, temperature range, etc. and what soil building can be expected from the life cycle. With that we might use plantings as soft infrastructure for a living mitigation measure rather than riprap or other structural methodology.

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

ASFPM draft national flood policy Page 26

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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. Interesting perspective. I would support this information on the maps, but would expect the local government and current owners and users to be a source of the information, not the newly educated. The buyers and developers would be educated and planners would be able to use this information to best direct development or lack of development.

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. (a) 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

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

ASFPM draft national flood policy Page 27

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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 Property ownership is voluntary, and unless the decision privatizes a public good to the detriment of the public, I don’t see a reason for the government to increase the forced placement of insurance. To some extent, we would be better off to refuse insurance to camps (many not actually built to any building code standard) or other substandard structures in an effort to encourage the decommissioning of those unsafe structures. Insurance encourages people to rebuild when they might not have been able to afford to without it. People with camps sometimes pocket the insurance doing minimal repairs and make a profit on the insurance proceeds. There is no limit to the number of times people can flood and get claims paid, and no connection between these claims numbers or values and the flood insurance premium. Requiring all structures to get flood insurance will get in revenue, but also increase payments and eliminate the incentives to mitigate that risk or pay off mortgages to eliminate the burden on the NFIP. FEMA must then stand firm and not pay disaster funding to people who were not insured encouraging rebuilding in place.

L.18. LiMWAs should not be optional and should be used on all coastal maps. See A 21 latter is covered elsewhere Agreed. See comments at A21.

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

ASFPM draft national flood policy Page 28

7-7-14 draft

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

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

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. Expand steam gauging network technologies to flood warning systems. O.10. Establish a combined review process for community/state compliance, mitigation, enforcement after a flood

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

ASFPM draft national flood policy Page 29

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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

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.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.

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.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

ASFPM draft national flood policy Page 30

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

P.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

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.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 Assistance grant eligibility contingent on NFIP participation and compliance and on maintaining flood insurance

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

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

ASFPM draft national flood policy Page 31

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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

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

R.4. {State who will} eEvaluate 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 working 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.

ASFPM draft national flood policy Page 32

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

R.13. Provide generous 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).

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

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.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 The LOMR LOMA process needs a complete review and having states and localities review submittals is one step.

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

ASFPM draft national flood policy Page 33

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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.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

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

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 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

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

ASFPM draft national flood policy Page 34

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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

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

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 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

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

ASFPM draft national flood policy Page 35

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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.

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 re- nourishment 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.

ASFPM draft national flood policy Page 36

7-7-14 draft

National Flood Policy—ASFPM 2015 Recommendations

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.

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.

ASFPM draft national flood policy Page 37

7-7-14 draft