The letter concludes: “Only by empowering FEMA with independence, recommitting to hazard mitigation and sustaining trusted and proven partnerships can we ensure that communities across the Nation are prepared to withstand and recover from the disasters we know are coming.”

Read the comments  

The comments submitted this week build on the previous comments ASFPM provided in July. 

The FEMA Review Council is expected to release a report in November with its recommendations to improve federal disaster response.

The post ASFPM Presses FEMA Review Council on Three Urgent Priorities for Disaster Readiness first appeared on Association of State Floodplain Managers.

We also highlight key challenges with implementing Section 406 mitigation, including the need to identify hazard mitigation opportunities early in the recovery process. Without addressing these process issues, simply offering a cost-share increase may not lead to meaningful improvements in disaster resilience. Additionally, ASFPM recommends expanding the criteria for cost-share incentives to recognize a broader range of state and local mitigation efforts. Read our full comments here.

The post ASFPM Submits Comments on FEMA’s Public Assistance Mitigation Cost Share Incentives Policy first appeared on Association of State Floodplain Managers.

NOAA’s Precipitation Frequency Atlas of the United States (Atlas) provides the statistical likelihood of an extreme precipitation event at a particular location in any given year, which — until recently — assumed a stationary climate. These statistics are the basis for planning and infrastructure design and for communicating the likelihood of extreme events, such as storms that have a 1% chance of occurring. 

Recognizing that extreme precipitation and nationwide flood risk are getting worse in a warming climate, NOAA is changing the methodology used to produce the Atlas by factoring the future state of the climate into official precipitation frequency estimates

Beginning with a pilot project for the state of Montana, on October 9 NOAA’s National Weather Service’ Office of Water Prediction released an early look  at the data used to produce Atlas 15 Volumes 1 and 2 to get stakeholder feedback before expanding nationwide. Volume 1 uses trends in observations and Volume 2 uses climate model output data to estimate future conditions. 

Novice and experienced users of Atlas tools are asked to review and compare both volumes and provide feedback on the utility of each interface. Doing so will be the first step in a robust peer-review process that Atlas 15 will undergo before it is published for the continental U.S. in 2026, and the rest of the country in 2027. Next year, NOAA will release preliminary estimates for the lower 48 states to begin the peer review process. When Atlas 15 is published, these data will provide communities across the country with information necessary to adapt to future climate conditions. 

The new Atlas will provide an update of the current Atlas 14 “point and click” system of spatially independent estimates of expected precipitation depth for specified storm durations from 5 minutes to 60 days, and is also presented as annual exceedance probabilities from 50 percent to 0.1% annual exceedance.  

The move to Atlas 15 will bring numerous benefits, including:

• Updated Historical Data: Atlas 15 will refresh outdated data to the present. Many Atlas 14 products are 10–20 years old.
• Seamless National Estimations: It will ensure consistent precipitation estimates across the entire country.
• Future Climate Projections: Atlas 15 will include estimates of future conditions based on different greenhouse gas scenarios going forward, and it will display these side by side for easy comparison.

Instructions for accessing the Montana Atlas 15 pilot can be found here, along with a six-minute video explanation of its features and a 36-page detailed explanation of methodologies employed in developing the Atlas. This represents a huge accomplishment that ASFPM has strongly supported over the past five years, as part of a larger effort to improve flood estimation and, ultimately, mapping accuracy. We encourage our members to review the pilot data and complete the NOAA survey. Feedback will be accepted through December 31, 2024

The post NOAA Atlas 15 Extreme Precipitation Pilot Dataset Released for Review first appeared on Association of State Floodplain Managers.

1. CRS’ Role in Comprehensive Flood Risk Management: ASFPM emphasized that CRS should not be viewed solely through the lens of insurance discounts. The CRS plays a broader role in supporting flood risk management by encouraging community-wide practices that reduce flood risk and support NFIP’s comprehensive goals. ASFPM cited studies demonstrating CRS’ success in reducing flood claims and noted we have received ample feedback from members suggesting that there is widespread support at the community level for the comprehensive approach CRS uses to promote flood risk reduction through various community-wide activities and elements.
2. A Simpler CRS for Everybody: ASFPM advocated for a simplified CRS program that reduces administrative burdens, making it easier for more communities to participate. We suggested the possibility of auto-enrolling all NFIP communities into CRS, provided there is significant simplification of the enrollment process and administrative requirements.
3. CRS Flexibility: ASFPM supports greater flexibility in how communities participate in CRS, including the question around allowing communities to exchange premium discounts for capacity building grants that could help fund floodplain management initiatives. Additionally, we recommended enabling regional participation models to help smaller or under-resourced communities engage in the CRS program.
4. A Holistic Approach to CRS Technical Assistance: To support a simplified and flexible CRS, ASFPM called for a coordinated technical assistance program that includes robust support from state floodplain management offices, FEMA regional offices, and external contractors. The goal is to ensure consistent, timely support for all participating communities, and that includes better use of data and improved training opportunities.

“By implementing the CRS program in the way we’ve outlined in these comments, it can also be made far more equitable than it is today. By ensuring all communities have the ability to participate in a simpler, more flexible program where technical assistance is abundant, FEMA can ensure that all communities and policy holders can reap the rewards of CRS participation.”

Download ASFPM’s comments

See all 96 comments submitted to FEMA

The post ASFPM Makes Recommendations for Strengthening CRS   first appeared on Association of State Floodplain Managers.

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:

1. 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.
2. 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.
3. 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.

Download ASFPM’s comments

Learn more about the National Levee Safety Program

The post ASFPM Comments on National Levee Safety Guidelines first appeared on Association of State Floodplain Managers.

The post FY24 Cuts Will Impact National Preparedness first appeared on Association of State Floodplain Managers.

Floods adversely impact American agriculture and rural communities — and the trend for the frequency and magnitude of these events continues to move in the wrong direction.

The EWP program currently only provides funding after floods have occurred, rather than preventing the damage in the first place. ASFPM would like to see the US Department of Agriculture (USDA) work with agricultural landowners and other partners to reduce the risk of catastrophic flooding through proactive voluntary measures to restore and maintain the function of floodplains.

Read the letter

The post ASFPM Seeks Farm Bill Improvements to Boost Resilience of Ag Communities first appeared on Association of State Floodplain Managers.

The current planning framework, called the Principles and Guidelines (“P&G”), which aims to “maximize monetized NED benefits” (while meeting the basic environmental requirements), was first adopted in 1983 when it was championed by the Interior Dept. Secretary James G. Watt, as he was acting as the chair of the now largely inactive U.S. Water Resources Council. In the 2007 Water Resources Development Act (Sec. 2031), and again in WRDA 2014, Congress directed the Army Secretary to make major revisions to the P&G, because they are now widely seen as unduly narrow. These changes have been held up for more than 15 years by a range of hurdles; however, some key first steps were taken by the Obama Administration in 2013 with adoption of a new, broader planning framework called the Principles and Requirements, followed in 2014 with adoption of cross-government “Interagency Guidelines.”

On February 15, 2024, the Corps issued proposed regulations (“ASP’s”) built on these two more recent documents that would substantially expand the range of benefits available for project or program evaluation benefit-cost analyses, making consideration of economic, environmental, and social effects to be “non-hierarchical,” and specifying additional principles to be pursued, including environmental justice, avoiding the unwise use of floodplains, healthy and resilient ecosystems, public safety, using a watershed perspective, and emphasizing sustainable economic development. The public comments period closed April 15.

ASFPM provided comments, broadly approving the proposed rules and their intentions, but also urging more detail be included in the regulations themselves, to give greater clarification and to limit potential for misinterpretation or unnecessary controversy. The rules are meant to apply to most types of projects (and programs) the Corps traditionally undertakes, including navigation, flood risk management, and ecosystem restoration and protection, but here, on a prospective basis. The agency received some 52 sets of public comments, with a large number supporting the need for broadening considerations and objectives in planning, including use of nonstructural approaches, and natural and nature-based designs to be considered early in the planning process. Most commenters recognized that the current analyses often exclude or very poorly-serve economically or socially disadvantaged neighborhoods and communities, especially in flood-risk reduction and ecosystem protection. It is the more expensive properties at risk that usually get the most funding and attention. It is not clear if the Corps will be able to complete the rulemaking process in the next few to several months, but we understand the Corps hopes to keep the process moving forward. The rule’s preamble discussion, draft rule and public comments are available on the Regulations.gov site. ASFPM’s comments are available here.

The post ASFPM Comments on USACE Proposed Rules for Agency Specific Procedures for PR&G first appeared on Association of State Floodplain Managers.

With that in mind, the ASFPM Policy Team has set the following priorities for the remainder of the 118th Congress and in working with federal agencies:

Download priorities for 2024

The post Legislative and Policy Priorities for Calendar Year 2024 first appeared on Association of State Floodplain Managers.

In our continued efforts to push for significant reform and long-term NFIP reauthorization, ASFPM has put together a detailed priority list of changes we’d like to see in the federal flood insurance program. The priorities address key components of the program, such as flood risk mapping, flood insurance, floodplain management, and flood mitigation, and the changes that ASFPM feels are necessary to strengthen the NFIP and advance equitable flood risk management across the nation.

Download ASFPM’s Detailed Priorities for FY24 NFIP Reauthorization and Reform

The post ASFPM’s Detailed Priorities for FY2024 NFIP Reauthorization and Reform  first appeared on Association of State Floodplain Managers.