NEWS

ASFPM’s Recommendations for Managing Flood Risk in the Nation

May 18, 2016 | News & Views

Section 1 (A, B & C): Flood Hazard
Mapping and National Data Sets

Flood maps show
areas in a community that will flood in a certain probability of flooding. They
have been produced since the 1950s and ’60s, when Jim Goddard at the Tennessee
Valley Authority worked with communities in the Valley to produce maps that
identified the 1 percent chance floodplain, then worked with the community to
adopt an ordinance to guide development within that flood hazard area. While some
local maps were developed (e.g. Maumee River in Ohio after the 1913 floods),
the TVA effort was designed as a model that could be used nationally to
implement the NFIP that Gilbert White espoused as a means to adjust human
behavior instead of adjusting our rivers and natural flood defenses.

The NFIP has spent more than $4.2 billion mapping flood
hazard areas over the past 37 years. That has resulted in flood maps for about
one third of the 3.5 million miles of rivers and coasts in the nation. About half
of those maps have a flood elevation included—meaning only about 1/6 of the nation’s
floodplains have a map with an elevation the community can use to guide
development. That also means the flood insurance program does not have accurate
flood elevations on which to base flood insurance rates in those areas.

NFIP flood maps are more accurate and will be better accepted
and utilized by communities if the community and the state are heavily involved
with the NFIP in producing the map. Many progressive communities provide local
funding to assist in producing flood maps, since the maps are utilized for many
purposes by the community, such as comprehensive planning, flood mitigation
planning and locating critical facilities like fire stations, water plants,
evacuation routes, etc.

The three basic elements needed to produce an accurate flood
map are: (1) hydrology or how much water will flow in a certain flood event (streamgage
records or other mean are needed to make those projections), (2) cross sections
of the floodplain so a hydraulic model can calculate how high the flood level
will get with that much water in the steam, and (3) a topographic map of the
land in and adjacent to the river or coast (including underwater profile) to
accurately calculate the flood level and to show the buildings and ground that
will be inundated when that level of flooding occurs.

One big advancement in the past 25 years is the technology
and process for topographic mapping. Forty years ago, we used USGS 20-foot contour
maps, and now mapping can be done using LiDAR technology to produce ground
level information faster and less costly, provide a more accurate depiction of
ground elevations, stream cross sections and even building footprints and types.

Accurate and timely data sets are essential for managing
flood risk. This includes everything from streamgage data of past flooding to
updated LiDAR mapping to the historical data of flood damages, a compilation of
disaster costs over time and location, and cumulative damages to buildings.

It is apparent that flood risk changes over time due to
increased development in watersheds, increased storm intensity and increased
development in flood hazard areas increased the consequences of flooding.
Changing climate has led to rising sea levels, which many coastal communities
are already facing. The recommendations here are focused on ensuring national
flood policies and programs help communities identify and adapt to the impacts
of climate change.

Subsection A. Ensure Flood Mapping, Hydrology &
Hydraulics

Produce
Accurate Flood Maps

Recommendation Explanation/rationale

Flood Map Funding and Oversight

A-1 MAP
FUNDING AND MAP MAINTENANCE

a)
Fully fund and implement the National Flood
Mapping Program (NFMP) as authorized by Congress in the 2012 National Flood
Insurance Program Reform (at $400 million/year budget from appropriated
funds).

b)
Fund map maintenance and regular map updating
as continuation of the NFMP.

[Congress, Federal
Emergency Management Agency (FEMA)]

Accurate Flood hazard area mapping is the
backbone of this nation’s flood resiliency and sustainability efforts.
Priority should be placed on enhancing map accuracy and completing flood
hazard mapping for the entire nation. Refer to the ASFPM 2013 Flood Mapping for the
Nation Report for an
estimate of the extent of expected costs involved.

Once developed, flood maps need to be
continually updated to stay accurate and relevant. Once all 22,000
communities are accurately mapped, policy fees should be able to fund map
maintenance.

To avoid falling farther behind in the
flood mapping and maintenance needs, annual funding at a substantial
(authorized) level is needed.

A-2
Continuously capture unmet mapping needs from the Map modernization (Map MOD)
and Risk Mapping Assessment Planning (Risk MAP) scoping, discovery efforts
and input from state and local partners in order to report to Congress/partners
an accurate scope of needed mapping efforts. Summarize these unmet mapping
needs by state and county and provide the data to Congress and the Technical
Mapping Advisory Council (TMAC) and NFIP state/community partners for their
information and use.

[FEMA,
states]

An accurate accounting of mapping needs,
by state and county, needs to be produced and shared with Congress (as well
as with TMAC) so that Congress has a clear understanding of the enormity of
the task at hand and can plan for a continuous funding stream needed to
fulfil the challenge.

TMAC needs this information to get a
handle on the scope of their tasks, and NFIP partners need it so they can do
yearly and long-term planning for mapping.

A-3
TECHNICAL MAPPING ADVISIORY COUNCIL

a)
Utilize and implement the recommendations of
the 2014 TMAC.

b)
TMAC should become a permanent council or
advisory committee.

See: A-5

[Congress,
FEMA, federal, states, local agencies]

When the 2014 TMAC recommendations are
made available, they will need to be funded and implemented.

Having TMAC as a permanent council would
insure Congress and FEMA have access to an independent, informed body of
knowledgeable mapping experts at any time when the need for such timely advice
would arise.

A-4 Consider
adding a $5 transaction fee to some flood map related activity, such as the Flood
Zone Determination performed as part of the closing of every property; with
the fee dedicated to flood mapping and map maintenance.

[FEMA,
Congress]

The transaction fee concept is something
that FEMA previously proposed as a way to help generate funds for flood
mapping and needs to be revisited. Some kind of fee is needed so all users of
the information help pay the costs of obtaining the information.

Refine
Flood Mapping Processes and Standards

A-5 MAPPING
REPORTS AND PROCESS

a)
Provide annual reports on the status of valid
map data, as reflected in the Coordinated Needs Management Strategy (CNMS)
data base, including data on modernized and non-modernized map panels.
Include in this report information on metrics used to define progress in
updating engineering data as recorded in the CNMS data base.

[FEMA]

b)
Whenever possible, engineering models used to
produce NIFP maps must be properly calibrated to historic flood events by
using the stage-discharge relationship at USGS gaging stations; or where gage
data is unavailable to historic high water marks to reduce the uncertainty
associated with the model results before such models can be deemed accurate
and acceptable.

[FEMA,
mapping partners]

c)
Periodically review and update the standards
for establishing valid map data to enable the identification of map data that
has been appropriately calibrated against historic flood events.

[TMAC,
FEMA, mapping partners]

d)
FEMA should discontinue the use of map panels
when producing FIRMs.

e)
Flood hazard maps should include the date of
the engineering study, topography and imagery, in addition to the date of
publication.

[TMAC,
FEMA]

See: B-1

In order to better understand the progress
in producing accurate, up-to-date flood maps, annual reports are needed on
the status of valid map data (as reflected in the CNMS data base) that would
include data on modernized and non-modernized map panels.

Streamgages
and high water marks (HWMs) on streams with no gages document historic flood
events.

Concerns have been raised regarding the
accuracy of FEMA’s flood hazard data. Unless engineering studies are
calibrated against historic flood events, it is difficult to quantify the
uncertainty of the flood hazard data being generated. The
reason calibrated maps can be deemed accurate is that while the uncertainty
can never be reduced to zero, it can be quantified. In instances where
engineering models have not been calibrated or validated against historic
flood events – the uncertainty is unknown, as is the accuracy.

Guidelines and quality assurance protocols
must be established for performing and evaluating all engineering and flood
models, including the unsteady and two-dimensional models.

Map panels are an outdated process that
adds costs and complexity to mapping. This will require working with Flood
Determination companies to ensure they have the data to perform their service
to the NFIP.

It is standard protocol in mapping to
include the date of the source information used to develop the map.

A-6
CALCULATING FLOODWAYS

a)
Change the minimum standard for designating
floodways to the “full conveyance floodway” concept and continue to allow no
(0.00 feet) impact for proposed encroachment into that floodway. A full
conveyance floodway includes all of the area inundated by the 1 percent
annual chance flood, except those shallow areas and embayment into small drains
and gullies where water would be ponding, but would not effectively convey
flood waters.

b)
Use this Full Conveyance Floodway to
designate NFIP regulatory floodways (instead of current procedures that allow
an artificial rise in flood levels 1 foot for NFIP and a variable amount down
to zero rise from state to state chosen by that state).

See: A-7,
D-10, D-15

[FEMA, TMAC,
mapping partners]

Under current procedures the NFIP flood
insurance study allows the floodway to be pinched in until the flood level
rises by a pre-determined amount (NFIP default 1 foot or in some states a
smaller threshold). However, the community is not required to adopt that
higher elevation, guaranteeing that those who build to the BFE will
experience a higher flood elevation and higher velocity due to permitted
fill in flood fringe areas that are really the natural floodway. The time
has come to accept the primary floodway corridor nature uses to convey flows
also as the regulatory floodway.

The 1-foot rise allowed by the NFIP results in a significant loss of
conveyance areas–the floodway width decreases by 32-68 percent and velocity
increases from 16-62 percent report here.

This recommended methodology does not
require any added calculations for setting the floodway limits.

A-7 Require
that for regulatory purposes the mapped floodway for an area with an
accredited levee include the entire footprint of the levee through its
landward toe, and that the regulations prohibit all development within the
prism of the levee.

See: A-6

[FEMA, TMAC]

To ensure that development and encroachment
within the prism (footprint) of a levee does not occur, the regulatory
floodway should extend to its landward toe. Too often, houses and other
buildings or development are allowed on the levee, leading to levee failure
or overtopping and making it impossible for levee owners to maintain the
levee.

A-8
Establish national program performance standards for all flood hazard-related
data layers (erosion, subsidence, closed lake basins, frazil ice, ice jams,
tsunamis, debris flow and mud slides, relevant wetland and groundwater) so
that data created by state, local, and other mapping partners can be readily utilized
by FEMA. Performance standards/protocols can be based on existing state or
federal entities that are already creating some of these products.

See: D-21,
M-12, D-18, N-2, N-3, N-6

[FEMA]

Not all flood hazard-related data layers
currently have a national program performance standard. Such national
standards are needed for program consistency so that data developed by FEMA
and other parties can be readily utilized and relied upon by FEMA and by
communities that use that data to reduce flooding and disaster costs.

A-9 DATA
LAYERS AND FLOOD ZONES

a)
Include various flood hazard-related data
layers where applicable (erosion, subsidence, closed lake basins, frazil ice,
ice jams, tsunamis, debris flow and mud slides, relevant wetland and
groundwater) on Flood Insurance Rate Maps (FIRMs) when data is available.

b)
Work with TMAC States/communities to establish
new Special Flood Hazard Area (SFHA) zones (such as an A zone for areas
protected by levees, A zone for areas protected by dams, or E zones for
areas subject to erosion, etc.) and related locally required regulations as a
condition to participate in NFIP and to discourage increased economic and
life-safety exposure and liability in flood risk areas.

See:
D-19, D-21, M-13, D-18, N-2, N-3, N-6, H-17

[FEMA,
TMAC, mapping partners]

Due to the significance of their impact at
a local level, some municipalities would like to show various applicable
flood hazard-related data layers on their FIRM and regulations specific to
each. FEMA should encourage this attitude and allow addition of these layers
to the FIRM when valid data is supplied. FEMA should also establish new SFHA
zones for these flood-related hazard layers so that flood insurance rates and
premiums can be accurately determined that are commensurate with the risk.

Flood insurance premiums for such zones
should be based on actual risk (i.e., in addition to expected damage
potential, qualified mitigation activities undertaken to buy down the risk,
such as levees, dams, etc., should be recognized).

A-10
Establish national performance standards for the development of data layers
capturing expected future-condition flood hazards (as a result of projected
sea level rise, likely flow increases due to uncompensated changes in
watershed land use, expected permitted development activities such as
cumulative filling of floodway fringe areas, climate change and other factors
affecting flood–related risks in the future) and allow inclusion of such data
layers on FIRM when data is available and requested for inclusion on FIRM by
a state or local mapping partner.

See: A-19,
M-5, M-12, C-1

[FEMA, TMAC,
mapping partners]

To be sustainable, communities need to
have access to reasonable expected future condition flood hazards data
layers. Coming up with national standards for production of such data layers
will be important for consistency and strategic planning at a national level.
Also, allowing and encouraging the incorporation of such data layers for the
community’s FIRM would make it easier for those communities that have such
data available and are willing to regulate at a higher standard implement
such best practices.

A-11 Expand
the Letter of Map Revision (LOMR) Delegation Program to allow delegation to
additional states and to state designated local authorities who are willing
and qualified to undertake this aspect of program. Review, streamline, and
strengthen current LOMR Delegation guidelines and qualification.

[FEMA, with
mapping partners]

Strengthening current LOMR delegation
guidelines would help FEMA and Cooperating Technical Partners (CTPs) evaluate their readiness to share
the workload in such a way that it results in a more sustainable system with
a better quality product at a lower price. Streamlining the process would
make it attractive to many more qualified partners to take on this task,
resulting in efficiency and reduced mapping costs.

A-12 Delete
the rounded, whole-foot elevations from the BFE lines (“squiggly lines”) on
the FIRM.

[FEMA]

There is no need to include the whole-foot
BFEs with the BFE lines now that BFEs to the nearest tenth of a foot are
listed on cross sections on new maps. The rounded BFEs only serve to confuse
map users and increase the cost of developing the maps.

Coastal
Mapping

A-13
Delineate Limits of Moderate Wave Action (LiMWAs) on all coastal flood maps,
with no-opt-out allowance for communities.

See: M-14,
D-13, E-1

[FEMA,
mapping partners]

Incorporation of LiMWAs on all coastal
flood maps will alert the regulating agencies of another unique flood hazard
zone that would require an appropriate specific set of standards; usually for
V zones.

A-14 Develop
a unique coastal A Zone definition for placing on the maps and provide that
definition in the Code of Federal Regulations (CFR).

See: M-14,
M-16, D-13, E-1

[FEMA]

The nature of coastal A zones is very
different from A zones in riverine areas. However, a separate definition for
each of these zones does not currently exist.

New Mapping Approaches

A-15
DELEGATION OF MAPPING

a)
Delegate authority and funding for mapping of
all flood hazards on NFIP flood maps to qualified state and state-designated
local authorities. This program should allow the mapping priorities to be
developed jointly by the authorized state and local partners, with input
provided by FEMA. Incentives should be developed to encourage state and state
designated local authorities to provide supplemental funding to enhance
“their” flood hazard mapping.

b)
Review and strengthen current CTP guidelines
and qualifications so that those state or local partners selected for
delegation would meet or exceed the FEMA’s minimum expectations.

c)
Require delegated states to develop and
maintain an archival system for all flood map models for data stewardship and storage in addition to
the Map Service Center. Encourage and provide funding incentives to all
states to archive flood map data in digital, electronically transmittable
form.

See: P-3

[FEMA, state
and community mapping partners]

Delegation and stewardship of mapping
flood hazards at the state level (and sometimes even at a local level) is
essential to this nation’s road to flood resilience. We should start this
process through baby steps of delegation to qualified/willing states and
state-designated local authorities who are qualified and have a track record
for such stewardship. Strengthening current CTP guidelines would help FEMA
and CTPs evaluate their readiness to share the workload in such a way that it
results in a less expensive, more sustainable system with a better quality
product.

FEMA’s regulations are
explicit in requiring the participation of the states in administration of
the NFIP. 44 CFR Part 60.25 Designation, Duties, and Responsibilities of
State Coordinating Agencies contains a list of duties and responsibilities,
including: (b)(6) assist in the delineation of riverine and coastal
flood-prone areas … and (c) Other duties and responsibilities, which may be
deemed appropriate by the state … may be carried out with prior notification
of the administrator.

When states are entrusted with production
and maintenance of flood mapping products, they should be required to
maintain an independent archival system so that all the mapping needs of a
state can eventually be fulfilled under the stewardship of that state. The
engineering models have significant value and therefore warrant redundant
archives. North Carolina is a best practices example.

A-16 Explore
potential changes to current FEMA practice with regards to funding,
production, storage, management, and stewardship of various data layers used
to produce FIRM or non-regulatory products. These changes could include FEMA
concentrating exclusively on the development, maintenance, and updates of
flood hazard-related data layers and rely on/link to other needed non-flood
hazard related data layers that currently are (or can be) under stewardship,
managed, and maintained by other federal or state agencies through either
independent or FEMA-supported cost sharing, to produce NFIP FIRM or
non-regulatory products. Under such a proposed scenario, each agency will
only be responsible for the accuracy of the layers under their stewardship.
Each data layer must have the proper supporting metadata, domain tables, and
other necessary certification and licensing information consistent with
FEMA’s minimum requirements. Also under this proposed scenario, FEMA must
maintain meaningful links to those non-FEMA maintained data sets, utilizing
the most appropriate data sharing protocols, and ensure that mapping related
data sets are available at least until any reference to them would only be
for historical purposes rather than regulatory, legal or insurance purposes.

[FEMA, with
guidance from TMAC, United States Geological Survey (USGS), mapping partners]

Currently, the responsibility for funding,
production, storage, management, and stewardship of various data layers used
to produce FIRM or non-regulatory products all rest with FEMA. This puts an
enormous burden on one agency and in many cases leads to duplication of
efforts by other federal and state agencies that have primary jurisdiction
and expertise over some of these data layers. This also distracts FEMA’s
efforts from ensuring that an accurate flood hazard layer is produced and
maintained for all the nation’s flooding sources. Agencies should focus their
efforts on producing and maintaining data layers (rather than maps) for
those products under their traditional stewardship (such as stewardship of
USGS with regards to topographic data layers, stewardship of FEMA with
regards to flood hazard-related data layers).

Flood hazard-related data layers include,
but are not limited to:

·
a fully
digital national flood hazard data layer (primary focus for NFIP);

·
coastal
erosion and riverine fluvial erosion/channel migration zones;

·
areas
protected by dams, levees, diversions, reservoirs, and other structural
projects (delineated simply by assuming the structural measure has failed); and

·
areas
with repeat flood damage claims and adjacent areas with repeat flooding
histories; and other special flood hazard-related layers (such as subsidence
zones).

A-17 The
NFIP should consider transitioning its “map” production system to a fully
digital decentralized system where a “map” is prepared through overlaying of
appropriate mapping layers applicable to a state or a local community. Printing
on demand, and distributing such mapping products can be delegated to
qualified mapping partners based on guidelines developed by FEMA.

[FEMA,
TMAC, and mapping partners]

Many state and local land use planning and
regulating agencies are already capable and/or will soon be capable of
producing their own “maps” through overlaying the hazard layers important to
them on local road maps or best aerial maps with the community boundaries
they maintain. This will bring about sustainability of the mapping program
and buy in at the state and local level. While this will not be implemented
overnight, it should serve as a long-term vision for future “flood map”
production in this nation.

A-18
Consider placing an expiration date on all Flood Insurance Studies and FIRMS
or flood data, as well as anticipated date of updates. An evaluation of the
accuracy and applicability of the FIRM data will need to be conducted prior
to expiration and the data either re-validated or revised prior to assigning
a new expiration date. Dovetail with planned map update funding cycles so
that the community is not penalized as a result of FEMA’s funding priorities.

[FEMA, TMAC,
mapping partners]

The current FIRMS are based on existing
conditions. Therefore some assessment should be made as to how long the FIRM
is reasonably accurate (likely max of 5-15 years). The duration of valid and
accurate data will likely differ based on uniqueness of hazards in each area
and outside influences (such as watershed development, change in rainfall
characteristics, presence of active subsidence, etc.)

Hydrology and Hydraulics

A-19 FUTURE
CONDITIONS HYDROLOGY

a)
Federal programs should incorporate
future-conditions hydrology and cumulative impacts of watershed development
and hydrologic changes into flood risk determinations. Such future-condition
hydrology should incorporate the impacts current and proposed flood-fringe
filling and watershed land use changes and of climate change.

b)
Simple alternative methods to account for
future-condition hydrology, such as using the 0.2 percent annual chance peak
discharge in place of 1 percent annual chance peak discharge in urban areas,
or using 125 percent of the 1 percent annual chance peak discharge, in lieu
of detailed analysis to determine the future condition 1 percent annual
chance discharge, could be utilized with justification when definitive
studies are not available.

c)
All federal projects should use future
conditions in planning, design and construction to avoid loss of level of
protection and adverse impacts on other properties.

See: A-10,
M-5, M-12, C-1

[FEMA, Mitigation
Framework Leadership Group (MitFLG), Department of Transportation (DOT), (Department
of the Interior (DOI), Environmental Protection Agency (EPA), National
Oceanic and Atmospheric Administration (NOAA), US Army Corps of Engineers (USACE),
Natural Resources Conservation Service (NRCS)]

Incorporating reasonably expected future
hydrology (likely changes that are unmitigated) into all federal programs is
necessary as a national security and sustainability measure. This should
include maps produced under the NFIP flood insurance studies as required by
the 2012 NFIP reform legislation. FEMA could show the resulting future conditions
floodplain boundary as an advisory flood boundary for insurance purposes, and
communities should consider using it for development regulation, and get
significant CRS credit.

Communities or states can use various
approaches to account for future development, and should ensure those
approaches do not externalize increased flooding and increased costs onto
other properties from the development.

Too often structural or development
projects have been constructed or improved on one side of the river, only to
raise flood elevations on the other side of the river or upstream or
downstream. Such impacts must be mitigated or flooding easements purchased
before construction occurs.

A-20 Require
the 95 percent upper confidence interval (instead of the current 50 percent)
for flow values used in flood map studies to provide for life-safety and to
account for uncertainties in determining regulatory discharges in a
non-stationary meteorological environment.

[FEMA, USGS,
Advisory Committee on Water Information-Subcommittee on Hydrology (ACWI – SOH),
mapping partners]

Studies have shown that contrary to past
assumptions, meteorological conditions are not stationary. In addition,
watershed development, frequency estimation errors or bridges blocked during floods
lead to underestimation of regulatory discharges and elevations. Utilizing
the 95 percent upper confidence limits is a prudent way to address
uncertainties regarding regulatory flows and to protect life and property.

A-21 Promote
the use of unsteady state models and 2-D models in appropriate situations,
such as those described in the ASFPM white paper (July, 2014).
Establish standards for 2-D modeling to show how they should be used in
appropriate situations to address uncertain flow paths.

Unsteady state and 2-D models can produce
more accurate results in some instances and their use should be promoted
where circumstances require such representation of the system.

Subsection
B.
Using Data & Technology to Support Flood Risk Management

Recommendation Explanation/rationale

B-1 Stream gage and Tide Gage funding

a)
Provide reliable federal funds for network of
nationally critical index stream gages (National Streamflow Information
Program (NSIP) and coastal tide and storm surge gages).

b)
Identify additional funding sources for
streamflow and storm surge data gathering and analysis of that data to inform
and include appropriate climate change information.

See: A-5

[NOAA, FEMA,
USACE, NOAA, Congress, administration,
MitFLG, Federal Interagency Floodplain Management Task Force (FIFM-TF)]

Federal funding for NSIP gages need to be
increased substantially. Right now the funding for the gage program is about
$110M/year and should be double that. The NSIP gages are nationally-significant
gages used for flood studies, warnings and evacuation and research, as well
as general data.

Establish an intergovernmental commission
to develop 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 and tidal gaging network and stream flow data
collection is becoming critical for flood risk management and long-range
emergency and watershed planning and standard setting.

B-2 Incentivize
state/local/regional participation in funding of locally or regionally
significant stream gages.

[FEMA, HUD,
USACE, DOT, NRCS]

This is happening now, but without
incentives; thus hundreds of gages are lost every couple years. Incentives
could come in cost share/grant points or CRS points.

B-3 Develop
mechanisms by which NWS/local warning systems can supplement stream gage
data, and provide that data in real time to help in the forecasting of
stormwater and urban flooding, and evacuations.

See: M-4

[NWS, USGS]

Lots of data is being generated, but it
must be shared in real time and utilized for cost savings and flood risk management
– some locals already do this. Rainfall/runoff models are used in many
places.

B-4 FLOOD
INSURANCE & DISASTER CLAIMS/DATA

a)
Make all data collected post-disaster
(including NFIP claims and damage assessment information) available and easily
accessible to states and communities in real time.

b)
Develop mechanisms where FEMA can easily and
quickly provide relevant damage assessment and flood insurance claims data
on-demand to state and local floodplain managers to support substantial
damage determinations.

c)
Encourage the consolidation of information
protected under the Privacy Act of 1974 into census block level data or some
similar aggregation of data so that the data can be used for planning,
analysis and research to assist in the improvement of the NFIP, flood risk
communication and disaster response.

d)
Seek the exemption of this data from the
Privacy Act either through legislation or by asking the attorney general to
clarify if all this type data is really subject to the Privacy Act.

e)
As a condition of receiving public assistance
(flood insurance, Small Business Administration (SBA) loans, etc.) the
property owner should have to sign a waiver of the Privacy Act, thereby,
making the information available (only relevant data, not personal data).

See: G-9,
E-8, F-15

[Congress, attorney
general, Department of Homeland Security (DHS), FEMA, MitFLG, states]

Currently data that is shared comes too
late, is incomplete, or is unavailable. Privacy Act concerns notwithstanding,
basic information related to damaged buildings should be easily available to
floodplain managers to help support their required NFIP duties in performing
substantial damage determinations.

Some state hazard mitigation officers (SHMOs)/NFIP
state coordinators/CTPs have access to some of this data and can release
jurisdiction-specific data to local governments withholding owner name and social
security number. Proactive states and local governments use the information. Some
academics have a non-disclosure agreement to use this data for research, but
not for general release, so it is not used for managing flood risk and
reducing disaster costs.

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 inhibited necessary
research and analysis to assist the improvement of many aspects of managing
risk and costs, especially in the NFIP and disaster program.

There should be accompanying development
of techniques/policies to use the data to help manage risk and reduce costs.

National Topography—LiDAR and Bathometric

B-5 PROVIDE FUNDING FOR TOPOGRAPHIC DATA

a)
Fund the USGS 3-DEP LiDAR initiative to
collect LiDAR 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 and protect property and lives.

b)
The nation desperately needs updated, high
resolution nearshore bathymetric data along all coasts.

See: E-9

[administration,
Congress, USGS , FEMA, NRCS, Bureau of Reclamation (BuREC), NOAA, states and
locals]

USGS has an eight-year plan to produce
nationwide LiDAR at the Quality Level 2 accuracy, called 3-DEP (3-D digital elevation program). Funding
sources is a combination of different federal sources, along with state and
local sources in order to reduce duplication of effort. This could be prioritized
where there is cost share or leveraged data.

These are important input data for FEMA
coastal flood models and for communities and states to manage flood risk on
all the nation’s ocean and great lakes coasts.

General Flood risk and Flood Damage Data

B-6 FLOOD
DAMAGE AND FLOOD RISK DATA

a)
Collect nationwide data on number of
floodprone structures, number of buildings that will be impacted by repetitive
loss by 2050 and 2100, dams and levees, population at risk. 2012 Reform act requires such data
as well as other critical data to be both collected and incorporated by FEMA
into future flood insurance rate maps.

b)
The MitFLG, 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 managing flood risk, flood damage reduction, disaster assistance, and
other federal construction, development, planning, funding and technical
assistance programs.

[MitFLG, Non-governmental Organizations (NGOs)]

c)
Generate a complete list of number and
location of residual risk floodplain buildings and infrastructure and level B-protected
buildings and infrastructure nationwide by making community participation in
NFIP, CRS, disaster assistance, Hazard Mitigation Grant Program (HMGP)
grants, approval of local hazard mitigation plans, and the Corps of
Engineers’ Rehabilitation and Inspection program (P.L. 84-99) contingent on
the community supplying and periodically updating this information.

See: B-7,
B-8, H-17, H-18

[FEMA,
USACE, states, communities]

One dataset that FEMA should support with
respect to this is building footprints. All CRS communities are now required
to report the number of insurable structures in their community each year,
and the change +/-. Class 4 and better are required to also report the number
of buildings impacted by a levee failure or dam failure.

TMAC can suggest means of ways to utilize
this data in mapping, however, FEMA is required to carry out these
requirements

Expand this to include the
“flood forensics” by year, that covers all flood damage cost;, flood
response, recovery, rebuild costs; who received the funds and what was the
source of funds [local, state, federal]. Use this data and information for
program evaluation and adjustment and to educate the 94% of population that
does not live in flood hazard area but pays the cost for the 6% that do live
in flood hazard areas.

Collection of the data on residual risk
structures and infrastructures should be eligible for cost share funding from
HUD, FEMA and other funding sources.

Historical, geo-referenced data about
deaths and damages can support practical measures to reduce potential impacts
and investing in early warning systems, retrofitting critical infrastructure
or enforcing new building codes, information and to assess the resilience of
a community, state or nation.

B-7
Establish nationwide database on disaster costs and the benefit/cost ratios
of mitigation activities, 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.

See: I-2,
H-6, H-17

[MitFLG,
FEMA, USACE, NOAA, NWS, HUD]

This data is needed because federal costs
for disasters are skyrocketing– potentially in trillions of dollars; average
federal share has risen recent decades from modest single
percentages years ago to 80 percent in recent major disasters. This Data is needed to better document
costs, trends and values of mitigation.

B-8 Disaster cost data

a)
Determine the true cost of disasters,
especially flood disasters, by research, with recommendations to develop a
mechanism to account for all the direct and indirect costs of a flood
disaster. Increasingly, it appears these cost may be 10 times greater than
current estimates.

b)
Create a comprehensive
database, standardized estimation techniques and framework for compiling
total loss estimates from individual disasters, including all federal
expenditures, economic damages, lost opportunity costs, insurance payments,
Individual and Public Assistance, etc.

·
This could be part of the National Climate
Data Center (NCDC) storm data collection effort

·
These data should be incorporated into the US
Department of Commerce (DOC) collection of economic statistics

See: I-1

[MitFLG,
FEMA, USACE, NOAA, USGS, NWS, DOT, SBA]

The FIFM-TF has started looking into this
issue, and has gotten as far as seeing what data exist now and what some of
the major gaps appear to be in terms of Federal costs/losses. Non-Federal/public
and private losses, which are clearly part of a “true cost” definition, have
not been collected yet.

Congress should fund this effort, but will
need a plan that lays out what is needed and cost. The lack of
a standard framework makes it extremely difficult to accurately identify
trends/causes in natural disaster losses. Moreover, this inability makes it
more difficult for the federal government to identify which disaster
mitigation policies represent the more cost-effective options.

The idea of
collecting these data and incorporating them into the DOC economic statistics
is a recommendation made by
the National Academies of Science (NAS) a decade ago.

B-9 Provide
full funding for flood risk management data gathering and development (flood
loss data, GIS, stream gaging, forecasting, mapping integrated ocean
observing system, research.

[administration,
Congress]

This must include tracking of flood loss
data over time.

Subsection
C.
Identifying and Adapting to

Increased
Risk from a Changing Climate

Recommendation Explanation/rationale

C-1 Develop
minimum Federal Flood Risk
Management Standards (FFRMS) for the expenditure of all federal disaster
dollars and grants that take into account appropriate impacts of changing
climate.

See: A-10,
A-19, O-1, G-6, L-1, D-1, H-2

[MitFLG,
FEMA, Council on Environmental Quality (CEQ), NOAA, USGS, USACE, academia]

MitFLG is working on this; appropriately
with all agencies. This could also include a community resilience index, if
appropriate. Providing guidance on use of climate informed science approach
to determining flood elevations for federal investment.

C-2
Support/fund/participate in data collection and analysis on impacts of and
adaptation to climate change.

See: B-6,
B-8

[USGS, USACE,
NOAA, FEMA, FIFM-TF, CEQ, states]

There is a lot of this currently being
done at universities and several federal agencies that needs to be folded
together and utilized. Climate data is being gathered and adaptations
prepared, which needs broad distribution/sharing/pilots (CEQ website, NOAA,
etc.)

C-3 Evaluate
regional/local vulnerability of US population centers to climate change
impacts and provide adaptation options, especially for increased intensity
and/or frequency of major storm events.

See: O-3

[CEQ, FEMA,
NOAA, USGS, National Science Foundation (NSF), NRCS]

Much of this information has been
developed or is being developed on a more regional/state basis and can be
utilized. Many agencies have already developed community options to address
the impacts.

C-4 Require
analysis of impacts and adaptations to climate in all federally-funded grants
and mitigation and community development planning for at least 50-100 years
or the anticipated life of the project if longer.

See: M-5,
F-1, H-2

[MitFLG,
federal agencies, states]

Design of all water resources,
transportation, community development, stormwater, water supply and
wastewater and mitigation projects should include future climate conditions
in the analysis.

C-5 Ensure
federal agencies prepare rules and procedures to implement EOs on adaptation
to climate change and resilience.

See: I-2,
O-1, O-2

[CEQ, Office
of Management and Budget (OMB), MitFLG]

The EOs include 13514, 13653; President’s
Climate Action Plan, impending Federal Flood Risk Management Standard (EO 13690).

C-6 All
levels of government should mitigate and adapt to the impacts and address the
causes of climate change in order to reduce the actual level of change that
future generations must endure.

See: O-1,
O-2, F-1

[MitFLG,
FEMA, USACE, NOAA, CEQ, NRCS]

Whatever local, state, and regional level
decision makers think are the causes of climate change, they should work to
address those to the extent possible. Individuals and communities
individually may have a small impact, but any action taken to decrease the
emission of carbon and other greenhouse gases helps.

C-7 Require
all Class 7 and better CRS communities to consider and plan for anticipated
climate change in their floodplain management plans. Class 1 communities
should prepare maps and regulations using best available data to address the
impacts of changing climate for the next 100 years.

[FEMA, CRS
Task Force]

It can also be added to the CRS catalogue
for credit by any community – some already are. This must include hazard
mitigation plans; although CRS only provides credit for floodplain management
plans, if not directly expressed would likely not be included.

Author