ASFPM wants to alert you to a notice in the Federal Register where FEMA is seeking comments on the update of several forms related to the acquisition of structures/property in conjunction with its Hazard Mitigation Assistance Programs, and on FEMA's proposal to exercise its authority to start an acquisition program directly with property owners (the state and/or community would not have to be involved).
We urge you to submit comments to the Federal Register by the deadline April 30, 2018.
ASFPM worked to get FEMA the authority to work directly with property owners in the 2004 NFIP Reform Act. At the time, nationwide there were reports where property owners themselves were willing to participate in a mitigation program, but the community and/or the state was not willing to develop an application on their behalf. As a result, there were repetitive loss properties that couldn’t be mitigated through a FEMA grant program. The authority written into the law mandates that a direct program could be implemented where a state and the community showed they didn't have the capacity to manage these grants. It was very important to our members that this authority be exercised in a manner that respected state and local efforts and didn’t undermine them.
ASFPM was quite surprised when this notice of rulemaking came out. Other than a short description in the Federal Register itself, the only other documents that gave insight into how FEMA would implement the authority was two proposed new forms. ASFPM has significant concerns with how FEMA would implement this authority, including the mitigation options that FEMA is proposing, the process they would use, including how and whether they would work with states and communities. ASFPM has already submitted comments to the Federal Register.
The draft FEMA forms are below, as they do not seem to be available through the Federal Register itself.
FEMA form 086-0-31 FRN
FEMA form 086-0-31a FRN
FEMA form 086-0-31b FRN
FEMA form 086-0-31c FRN
To submit comments to the Federal Register:
1) Go to the site www.regulations.gov
2) In the search bar type FEMA-2018-0006-0001
3) Click the “Comment Now” button on the right hand side
4) Type your comments into the form, include requested additional information and then click “Submit Comment.”
If you have questions, please contact the ASFPM Mitigation Committee Co-chairs Mitch Paine firstname.lastname@example.org or Joy Duperault email@example.com; or Larry Larson firstname.lastname@example.org or Chad Berginnis at email@example.com at the ASFPM executive office.