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 UseWhen zone D is used to depict “Undetermined hazard” only on lands under federal ownership such as National Parks. associated with Structural project, require flood insurance 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. If requiring insurance in areas protected by levees, consider the establishment of some level of regulation for these other protected areas.
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 flood hazards (coastal and riverine erosion, subsidence, sea level rise, storm surge) on flood maps, using a 150 years-into-the-future standard. These should be based on current medium to high GHC scenarios. Current estimate of average U.S. residential structure life is 150 years. Also see L.3
A.4. Include special hazards in producing FISs and on FIRMs (stream mitigation zones, ice jams, flash floods, closed lake basins, debris flow, alluvial fan etc.) Also see M.1, N.1, N.2Also see M.1, N.1, N.2Also see M.1, N.1, N.2by either representing a State or local community’s mapping or by creating a national program performance standard. A standard protocol can be recognized from existing state programs who are doing such work. Also see M.1, N.1, N.2
A.5. Map and designate propertiesareas with repeat flood damage claims and adjacent areas with repeat flooding histories (in all flood zones (SFHA and outside SFHA)areas where flooding damages are experienced)including flooding from stormwater) as floodplain, for regulation and insurance Effort should be made to identify and map not only specific “repetitive loss” properties, but also other adjacent areas with documented, repeat-flooding histories, whether or not they technically meet NFIP repetitive loss or severe repetitive loss definitions. NFIP should institute a surcharge for every claim or so, similar to auto insurance. Repetitive loss properties can serve as key locations for investigations on “repetitive loss areas.” Also see G.10
A.6. Allow non-regulatory products or other simplified processes to be used as a better way to assign flood risk for insurance purposes, either through separate map or other means, then use flood maps for regulation/planning/management. Non-regulatory products should only be produced with FEMA mapping dollars where the additional cost in minimal, as there is often a shortage of flood mapping dollars around the country.
A.7.(a) Fully fund and implement National Flood Mapping Program (NFMP) as directed by Congress in the 2012 NFIP Reform
A.87. (b) Fund map maintenance and regular map updating as continuation of the National Flood Mapping Program and Risk Map., This should be done outside of the NFIP policy and fee budget to the full authorized BW-12 levels ($499 million/year).
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)and other flood hazards as part of the 1% annual chance standard.
A.11. (a) Develop a coastal A Zone definition and provide that definition in the CFR, and look to include Coastal A Zone mapping in large inland lakes.
A.11.(bA.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
A.11 (bc) Map and change the V-Zone standard from 3’ breaking wave to 1.5 foot waves in 1-percent chance event as supported by FEMA research and analysis.. Depict 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. Increase the use of Coastal A zone mapping (including LiMWA) on large in-land lakes where appropriate.
A.12. (a) DelegateProvide FEMA the authorization to delegate authority and funding for mapping of all coastal and riverine hazards on NFIP flood maps to qualified states that request such authority under the Cooperating Technical Partners program., and shall undertake the mapping in accordance with standards that equal or exceed FEMA’s mapping standards.)
A.12. (b) Require CTP delegated states to develop and maintain an archival system for all flood map models for data stewardship and storage. Encourage and incentivize all states to archive flood map data in a digital, electronically transmittable format..
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. To achieve this type of approach, local capabilities need to be built to allow for local administrators to be able to use a fully GIS-based system. Additionally, the viability of this approach should be fully researched to see what drawbacks and benefits may result with such an approach.
A.13. Increase use of CTPs for delineating all coastal and riverine hazards on maps. In order to ensure that such an approach will be successful, current CTP guidelines and qualifications should be reviewed and strengthened so that resulting products are of the highest quality.
A.14. Delegate authority to review LOMRs to qualified states and state designated local authorities, with local review/sign off as needed. Again, to ensure that this approach is successful, strict standards and guidelines would need to be developed and implemented so that states and local authority LOMC review can be a successful program.. Also see S.4
A.15. Produce all flood maps in geospatial data format allow all such data as a substitute for traditional paper products ; require LOMRs to be in the same geospatial format, including updated databases
A.15.(a) require LOMRs to be in the same geospatial format, including updated databases, and be incorporated into the digital layer.
A.16. Map floodplains and other flood hazards of to the upstream source to a specific minimum watershed size or appropriate minimum unit for the mapped hazard. Also see G.2, T.8
A.17 If we continue to agree with the use of the 1% annual chance flood event as an inundation and velocity zone standard, the hydrologic record needs to be more frequently revisited to ensure that the record is including recent flood events and frequencies for predictive modeling. A 17. Make past flood maps readily available in digital, electronically-transmittable format
A 18.(a) Map floodways based on no cumulative flood rise and no adverse impact on other properties
A.18. (b) In preforming flood studies where an existing 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 2D models flow models to account for the loss of storagelateral flow. Due to the high costof modeling, this level of analysis should be commensurate with the level of risk. An alternative method of protecting floodway areas should be developed. Such an approach could use a more conservative floodway standard (no fill or structures regardless of rise, accounting for no increase in velocities as well as flood heights, etc.) to account for floodway impacts.
A.21. LiMWAs should not be optional and should be used on all coastal maps or on larger in-land lakes.
A.22. V-Zones should be mapped on all the Great Lakes or other large in-land 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, as well as the area impacted by a dam failure, where that information is known.
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.
A.24. Produce future conditions mapping that includes all scientific and planned projections of sea level rise, increase in riverine rainfall, watershed changes due to development and accounting for watershed development regulations that are in place, etc. , etc.
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.
A.27. Consider the use of better flood risk communication terms; rather than using “A zone” and “V zone”, develop a better term to communicate risk, as well as better terms to represent the continuation of risk throughout the floodplain and community.
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, such as…..
B.4. (a) Incorporate future-conditions hydrology and cumulative impacts into flood risk determinations under the NFIP. Flood insurance studies should identify assumptions for hydrologic estimates, especially for future conditions; adjust planning and regulation to avoid transferring the responsibility from those that cause the problem to those that suffer the consequences.
B.4.(b) Ensure that the cumulative impacts of encroachments be incorporated into all flood risk determinations such that there is no resulting increase in flood elevations without associated mitigation actions
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 through the use of USGS Flood Inundation Mapper to reduce the uncertainty associated with the model results before such models can be deemed validated. ....The USGS Flood Inundation Mapper uses flood inundation libraries to produce real time flood inundation predictions.
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, while incorporating and accounting for the natural ecology of a system to avoid over-engineered approaches to flood mitigation.
B.10 Future conditions hydrology should look at both future floodplain loss and future changes in hydrology
C. Stormwater & Watershed Management
C.61. Offer a national definition of watershed management that encompasses the range of watershed resources to be managedment and protected and the importance of runoff management.
6.2. Encourage or require watershed management regulations that prevents an increase in flood flows by new development or redevelopment with attention to the via control of not only peak flows, but also the volume of runoff and the timing of runoff for a continuum of storm events..
C.1. Emphasize integration of water quality and quantity (flood loss reduction) programs and Recommend or require foster holistic natural floodplain function and no adverse impact stormwater watershed management approaches or regulations at state and local levels. This should be done for the reduction of runoff, for the reduction of flood damage throughout watersheds, and for the protection of water quality and groundwater recharge.
C.1. Emphasize and foster the integration of water quality programs with in all watershed management approaches at state and local levels
C.2. Consider both flooding and water quality in all FEMA HMGP and Environmental Protection Agency Section 319 demonstration projects
C.3. RequireRequireRequireRequireThrough community planning (i.e. stormwater master planning), Rrequire 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
C.4. Encourage/incentivize (CRS and other) runoff reduction, rainfall and runoff infiltration, low impact development and green infrastructure techniques to reduce and manage flood flows and runoff, water quantity and water quality.
C.5 Apply and expand NFIP Community Rating concept to allow EPA and FEMA to credit community actions to reduce stormwater and urban flooding risk and to improve water quality and green infrastructure. Credits could come in form of advantageous sliding cost-shares for grants, disaster assistance, or other incentives.