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ASFPM Requests Member Comments on Corps’ Draft FFRMS Implementation Guidance

by | Dec 22, 2016 | News & Views

ASFPM
Requests Member Comments on Corps’ Draft FFRMS Implementation Guidance

The
Corps of Engineers has issued draft that outlines how it will implement the new
flood risk management standard to protect federal taxpayer investments in
federal actions. The Corps will do this not with rules in the Federal Register,
but by amending internal guidance they have used for years to implement the old
EO 11988. They have put the draft
EC out for comments, which are due to USACE on or before Jan. 30, 2017.

ASFPM
is asking all of you who wish to provide feedback for consideration into
ASFPM’s comments to please submit to either Executive Director Chad Berginnis (cberginnis@floods.org)
or Director Emeritus Larry Larson (Larry@floods.org)
by Jan. 25. If you can, we urge you to submit your own comments to the Corps as
well. The more the better!

Here
is link to CFR with summary and other data on Engineering Circular process.

Unlike
FEMA and HUD, which have opted to use the freeboard approach to establish the
elevation and horizontal extent of the FFRMS floodplain, USASE indicates on
page 8 of the draft EC, “All Corps actions subject to the FFRMS will utilize
the [Climate-Informed Science Approach], unless compelling justification for
using one of the other approaches is developed and documented”. It goes on to
say that decision must be approved up the line.

The
draft EC indicates CISA
will be calculated using Appendix H of the guidelines issued Oct. 8, 2015
for use by all federal agencies. The guidelines discuss use of SLR estimates in
coastal areas, and the need to determine new hydrology in riverine areas taking
into account projected increases in rainfall and land use changes. It
acknowledges FEMA is not yet mapping future conditions, including coastal
erosion as required by BW-12, and it provides links to a variety of resources
to assist agencies in making CISA determinations and promotes determining local
conditions (or use of local information where appropriate). Appendix H starts
on page 57 and goes to end of doc. It’s good on coastal, but weaker on the
process to use to determine CISA in riverine areas.

BTW, all of this info in on FFRMS page of our web site, which has a link on
front page. We will update that web page with the Corps draft EC info. Learn
more here
on ASFPM’s FFRMS page.

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