ASFPM Comments on National Levee Safety Guidelines
On Aug. 31, ASFPM submitted comments regarding the National Levee Safety Guidelines, the draft of which was made available for public review and comment earlier this summer.
ASFPM’s comments on the guidelines are largely favorable. We noted that we appreciate the user-friendly design and comprehensive approach, which make it a valuable resource for decision-making in levee and broader flood risk management. ASFPM also commended the inclusion of case studies and the recognition of the importance of natural floodplains and the needs of underserved populations.
However, ASFPM also raised a few concerns:
- Overemphasis on Levees: While the guidelines do discuss alternative flood risk reduction options, ASFPM feels there is too much focus on levees as the primary solution. The potential downsides of relying on levees, such as operational and maintenance costs, design limitations in a changing climate, and the misconception that levees eliminate all flood risk, are not sufficiently emphasized.
- Conflict Resolution and Impact Outside Levees: The document does not adequately address conflicts that can arise when the levee owner is not the community affected by the levee. Additionally, the impact of levees on people and natural systems outside the levee should be more prominently discussed.
- National Flood Insurance Program (NFIP) Requirements: ASFPM noted that the guidelines do not sufficiently address the requirements for levees in the NFIP, particularly how levee condition and function impact certification and the potential need for changes to Flood Insurance Rate Maps.
Overall, ASFPM supports the guidelines but suggests these concerns be addressed to ensure a more balanced and comprehensive approach to flood risk management.
