ASFPM M&ES Committee Comments on Spring 2016 Risk MAP Guidelines and Standards

ASFPM M&ES Committee comments on the latest proposed changes to the Guidelines and
Standards for spring 2016 are below in blue. (March 2016)

SID 43/Elevation Data

All updated flood hazard data shown on the Flood Insurance Rate Map
(FIRM), in the FIRM Database and Flood Insurance Study (FIS) must be based on
the best available existing topographic data and the data must have
documentation that it meets the following vertical accuracy requirements. If
data is not available that meets these requirements, new elevation must be
obtained.

Comment: ASFPM has long supported the notion that accurate
flood maps are critical and underpinning those maps has to be good topographic
data. In fact, in our report Flood Mapping for the Nation, is based on
the following assumption: “Up to date detailed elevation data (LIDAR or other
topographic maps) are needed anywhere flood mapping and data are to be
generated. “However, we want to ensure that if a state or community has data
that actually meets these requirements, then they can use it. Too often mapping
project budgets or metrics end up resulting in some of this topo data not being
used in FIRM and FIS updates. For example, Hennepin County, Minnesota will have
new countywide flood maps coming out in the next few months. Even though the
Preliminary maps were produced nearly 10 years ago and accurate LIDAR data was
produced 5 years ago (after the project was scoped but not so late that the
data couldn’t be incorporated onto the new maps) these new FIRMs will not be
using the best available topographic data which has a significant impact
overall on the credibility of the flood mapping program.

Secondly, ASFPM recommends that this standard does not
delay the modernization of the rest of the unmodernized flood mapping
inventory. In other words, an overall program priority must be to modernize the
mapping inventory and if those areas need accurate topo FEMA should ensure that
the resources are available to both develop the elevation data and modernize
those areas. We do not want to see the standard 43 being used as an excuse to
not modernize flood mapping for an area.

SID 507/FIS/FIRM

The FIRM, FIRM database, Flood Profiles and Floodway Data Tables must
all be in agreement with each other, including decimal point precision, as it
relates to the depiction of flood hazards and hydraulic structures.

Comment: It is understood that the FIRM DB should match the
FIRM and FIS; but in order to make that happen in some instances the mapping
partner cannot stay true to the model data. In cases where we are instructed to
eliminate, truncate or round model input and output data to satisfy database
and cartographic standards, the H&H MIP submittal will not match the FIRM
DB or profiles. This is a concern that we are losing vital engineering
information from the model in order to represent the floodplain data
cartographically. It may be difficult for a professional engineer to certify
the floodplain map if it does not adequately reflect the model output. Changing
the cross section shapes also makes it much harder to recreate and revise a
hydraulic model for LOMR or other purposes.

SID 602 & 621/Coordination

602: Before commencing the analysis and mapping activities that take
place during the Data and Product Development Phase of a flood risk study,
Project Teams shall provide a written notification to community Chief Executive
Officers and Floodplain Administrators that explains the selected modeling,
explains why the selected modeling is appropriate, and provides a 30-day period
for communities to consult on the appropriateness of the modeling.

603: Upon completion of the first Independent Data Submission for all
flood risk studies, Project Teams shall transmit a copy of the Independent Data
Submission package to the affected community Chief Executive Officers and
Floodplain Administrators and provide a 30-day period during which the affected
communities may provide data to FEMA that can be used to supplement or modify
the existing data, and incorporate any data that are consistent with prevailing
engineering principles.

ASFPM encourages input and collaboration between all
mapping stakeholders and understands FEMA’s desire to adhere to the HFIAA
legislation to provide communities with additional opportunities for review
during the flood mapping process. There is an inherent value to sharing project
data during data development and prior to preliminary issuance. Draft or
provisional data (data that has not gone through FEMA review) is shared by the
various mapping partners and regions when the requestor understands the
provisional nature of the data and that the data is subject to change and
revision. This sharing of data is commonly heavily caveated to the intended
user (such as when provisional study data is provided for an upcoming LOMR). There
is a concern that developing standards that require sharing draft or
provisional data without some explanation to the end user would introduce
additional risk to the mapping partner and a misunderstanding of the
provisional nature of the data could impact the technical credibility of the
final flood maps.

While transparency in the flood study process is
beneficial to the mapping partners, communities, stakeholders and FEMA there is
a concern that the vagueness of the language in the new 620 and 621 standards
could be used to indefinitely delay the flood mapping process. The addition of
two new comment periods also opens up mapping partners to additional costs that
were not included in the MAS or original project budget. There is also a
question if this applies to studies FEMA has funded, or if it would it be
applied to locally funded studies and LOMRs. In addition, standards should be
written in a way that is understandable by mapping partners.

The proposed new standard 620 requires a written
notification and explanation of the selected models and provides a 30-day
period for communities to consult on the appropriateness of the models. This
seems to be an extension of the existing requirement to do so during the
Discovery process/study initiation and seems to be duplicative. Also it is not
clear if a new comment period would be required if the engineer later
determines that he selected model is not the best model for the situation (such
as requiring a small segment of a 2D model to better model the flood
conditions).

The proposed new standard 621 appears to provide a
similar 30-day comment period after the engineering studies are complete;
however, the wording of the recommendation is overly confusing. The inclusion
of the ‘Independent Data Submission’ terminology—which is not currently a term
used in the flood mapping process but is taken directly from the legislation—
should not be used in the standard. Coastal flood studies use a similar
terminology (Intermediate Data Submission) for established data submissions in
a coastal study. Initially this standard appears to be an extension of the
proposed new standard 620 for the selection of models used in coastal studies. Assuming
this is intended to be an additional comment period after the engineering
studies are complete, FEMA should word the standard using terminology commonly
used in the flood mapping program. For example, this appears to be referring to
the flood study review process that was common prior to Risk MAP and FEMA’s
desire to direct the conversations away from the location of the flood hazard
delineations (line on the map) to a discussion of flood risk. If the desire is
to go back to the flood study review process, then providing terminology that
is clear to the intent of the standard such as review of engineering
studies/models and workmaps should be used.