National Flood Policy—ASFPM 2015 Recommendations
Training and Outreach Committee Recommendations for:
· Section E: Data & Technology
· Section Q: Partnerships & Incentives
· Section R: Federal Leadership
· Section S: Building State & Local Capability
· Section T: Individual Accountability
· Section V: Climate Change
· Section X: Resilience
Overall T&O comments:
· A few of the recommendations say who should be doing the implanting (such as “FEMA should” or “States should” – or, in one case, “ASFPM should”) but most of the recommendations are left without a recommended implementer. I don’t know if this is purposeful, but for consistency, consider adding an implementer to all or deleting them from the few that have them.
· We did not go through and do any grammatical/editing changes. However, the TO Committee leads are willing to help with that once the next iteration of the document is ready.
· Though we were not specifically assigned Section A, we have included below several comments related to that section, as flood maps are a way to communicate flood risk and this is of interest to us. A few comments are also included for Section B.
· We deleted any section for which we had no comments.
· Thank you for allowing us to assist in this effort. We learned a lot just going through all the recommendations and considering each in turn.
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.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 (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.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
A.6. Allow non-regulatory products or other simplified processes to be used as a better way to assign flood risk for insurance purposes, either through separate map or other means, then use flood maps for regulation/planning/management
A.7.(a) Fully fund and implement National Flood Mapping Program (NFMP) as directed by Congress in the 2012 NFIP Reform
A.7. (b) Fund map maintenance and regular map updating as continuation of the National Flood Mapping Program and Risk Map
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 (as part of the 100 year standard)
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
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) Delegate authority and funding for mapping of all coastal and riverine hazards on NFIP flood maps to qualified states under the Cooperating Technical Partners program.
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
A.15. Produce all flood maps in geospatial data format & allow all such data as a substitute for traditional paper products ; require LOMRs to be in the same geospatial format, including updated databases
A.16. Map floodplains to the upstream source Also see G.2, T.8
A 17. Make past flood maps readily available in digital, electronically-transmittable format
A 18.(a) Map floodways based on no cumulative flood rise and no adverse impact on other properties
A.18. (b) In perreforming 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
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 where the modeling shows that conditions meet V-Zone definition requirements, as well as the special hazard of ice.
A.23. An informational layer should be provided to all communities downstream of a dam showing the SFHA assuming the dam is removed.
A.24. Produce future conditions mapping that includes all scientific and planned projections of sea level rise, increase in riverine rainfall, watershed changes, 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. Flood maps or associated non-regulatory products should communicate risk to the public in a way the public can understand. For instance, the maps could convey an area of risk to life safety during the 1% annual chance flood based on the areas where flood water depth and flow could sweep someone off their feet.
A27. An effort should be made to communicate the risk represented by the return period of a flood as the areas where a flood is likely within the anticipated lifetime of a building or mortgage.
A28. FEMA should delete the rounded, whole-foot elevations from the BFE lines (“squiggly lines”) on the FIRM. While it is understood that the BFE lines are included to show water flow and assist the user and may be beneficial, there is no need to include the whole-foot BFEs with the BFE lines now that BFEs to the nearest tenth of a foot are listed on cross sections on new maps. The rounded BFEs only serve to confuse the user in an already complicated process to obtain a BFE at a property or structure for insurance and regulatory purposes.
A29. Federal agencies producing hazard and risk-identifying products to communities, citizens, insurers, etc., should keep the end-user in mind when designing such products.
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.
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 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
E. Data & Technology
E.1. Provide reliable funds for streamgaging 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 streamgages.”
E.2. Fund and update and maintain list of critical index stream gages (NSIP) nationwide—federal funding of this network is essential.
E.3. Develop mechanisms by which NWS/local warning systems can supplement stream gage data
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.
E.5. Develop open-source tools for post-flood damage estimation
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
E.9. Determine the true cost of disasters by developing a mechanism to account for all the direct and indirect costs of a flood disaster. Increasingly, it appears these cost may be 10 times greater then current estimates.