National Flood Policy—ASFPM 2015 Recommendations
A. Flood Mapping 7-7-14 draft
A.1. Depict failure zones (“protection zones”) associated with dams, levees, diversions, and –reservoirs or other structural projects on maps; where mapped at a minimum, map as A Zones and mandate regulatory action, flood insurance (Preferred Risk Rates if warranted) and mitigation within said failure zones. When Use zone D is used to depict “Undetermined hazard” associated with a Structural project, requireon lands under federal ownership, such as National Parks, only. 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 / riverine hazards (erosion, coastal erosion, subsidence, scientific and planned projections of sea level rise, storm surge, increase in coastal / riverine rainfall / storm events, watershed changes) on flood maps, using a 150 years-into-the-future standard (future conditions mapping). 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) HM / PDM grant standards to allow for communities to apply for grant funding to establish GIS layers for subsidence, channel migration, coastal / riverine erosion, sea level rise and other risk factors ,(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. Maps produced by CTP states must be to FEMA standards or higher.
A.12. (b) Require CTP delegatedall 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 ;
A.15.(a) 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 (No Rise / Zero Rise) and Nno Aadverse Iimpact on other adjoining properties (Should we somehow reference future conditions mapping here? Isn’t that what this is talking about in essence?)
A.18. (b) In preforming performing flood studies where the levee is assumed to contain the 1% chance flood, use the top of the levee or landward toe of the levee as the landward edge of the floodway.
A.19. Map floodways based upon a combination of depth and velocity of the water to show the true hazard and risk to property owners and communities; include as a standard NFIP flood map product
A.20. When scientifically justified, 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, as well as the special hazard of ice.
A.23. An informationalA regulatory flood layer should be provided to all communities downstream of a dam showing the SFHA assuming the dam is removed (i.e. inundation during the 1% annual 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, 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) The CFR requires NFIP participating communities to provide an updated corporate boundary limit within 6 months of any corporate boundary change. Institute a penalty system for any community that fails to meet this requirement (Ex $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.26.(a) above within 60 days of notification by the NFIP participating 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
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
C. Stormwater Management
C.1. Emphasize integration of water quality and quantity (flood loss reduction) programs and foster holistic and no No adverse Adverse impact 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
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.
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.
C.7. Wetlands and other storage areas outside of the SFHA should be preserved to prevent downstream increases in flood frequency and heights.
C.8. EPA, as part of MS4 permits should require the control of the peak and volume of runoff to greater than the 2-10 year events the 1% annual chance event, or greater, as warranted by stream conditions / historical flood characteristics, etc, to prevent the erosion of stream channels, pollution, and damage to adjoining structures which creates more pollution.
C.9. Consider requiring building setbacks/buffers from all streams and coasts with that area preserved in their natural state to reduce flood and ecosystem damages and preserve water quality.
C.10. EPA guidelines for watershed management plans should include the impacts of flooding and the impacts of development and the hydrologic regime and flood risk.
C.11. As a prerequisite for Class 4 CRS communities must require all new development and redevelopment to fully use LID techniques to mitigate their impact.
D. Water Quality
See C. Stormwater Management
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