While ASFPM supports the goal of helping disaster survivors rebuild as quickly and safely as possible, we strongly disagree with the approach taken in this rule.

What the IFR Rule would do: 

• Authorize federal preemption of any state or local permitting requirement that results in more than a 60-day delay for SBA disaster loan recipients
• Allow recipients to proceed with reconstruction through a federal self-certification process in lieu of going through a state or local permitting process
• Prohibit certain state and local enforcement actions, including stop-work orders and penalties 

In effect, the rule creates a pathway for rebuilding to move forward without traditional local permitting processes once a 60-day threshold is reached. ASFPM believes this approach is a misguided solution to speed up rebuilding, raises concerns about the rule’s legality, and outlines a few practical alternatives that would truly help speed recovery while preserving resilient rebuilding standards. 

Recommended steps include:

• Expediting federal reimbursements for debris removal and infrastructure restoration so communities can stabilize more quickly.
• Strengthening mutual aid systems to help surge permitting capacity in overwhelmed jurisdictions. 
• Providing direct federal support to local permitting offices following disasters.
• Examining delays in insurance settlements, which often slow rebuilding far more than permitting itself.

These types of targeted interventions would accelerate recovery without undermining the state and local standards that protect lives, property, and long-term community resilience. Download the letter 

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We strongly oppose any proposal to eliminate, divide, or weaken FEMA or its critical functions and programs—including the National Flood Insurance Program (NFIP).

The comments were submitted in three separate documents: 

Eliminating or Breaking Apart FEMA Would Seriously Weaken Disaster Assistance and Risk Management – Download comments

The Critical Nature of the National Flood Insurance Program (NFIP) in Saving Lives and Properties – Download comments

Issue Brief: FEMA’s National Flood Mapping Program and the Importance of Flood Hazard Identification & Risk Assessment to the Nation – Download

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

The post ASFPM Submits Comments to FEMA Review Council first appeared on Association of State Floodplain Managers.

Key points from ASFPM’s comments include:

• FEMA plays a critical role in making communities, and the nation, more resilient. Its work across all four phases of disaster management—preparedness, response, recovery, and mitigation—has helped protect lives, property, and local economies.
• Eliminating FEMA would undermine decades of progress in disaster management. ASFPM strongly opposes any proposal to dissolve or eliminate the agency.
• Restoring FEMA’s independence as a Cabinet-level agency would improve accountability, streamline operations, and allow the Administrator to advocate more directly for the urgent needs of disaster survivors.
• The National Flood Insurance Program (NFIP) must remain intact and housed within FEMA. Its four pillars—floodplain mapping, flood insurance, regulations, and mitigation—are foundational to national flood risk management and directly support FEMA’s broader mission.
• Incentivizing state leadership in hazard mitigation is essential. ASFPM supports restructuring mitigation programs to reward proactive state investments—such as maintaining complementary state programs, adopting resilient building codes, and advancing mitigation planning. Tools like a Public Assistance Disaster deductible and state allocations of BRIC funds could accelerate project delivery, simplify administration, and build long-term capacity. These changes should be phased in thoughtfully to give states time to prepare.

In short, ASFPM urged the Review Council to keep FEMA but fix what’s broken.

We stressed the importance of strengthening FEMA’s capacity and leadership at a time when natural disasters are becoming more frequent and severe. Continued investment in FEMA’s core hazard mitigation and resilience programs remains one of the most cost-effective strategies the federal government can pursue to reduce disaster costs, support state and local governments, and protect communities nationwide.

Read the full comment letter

NRDC produced a summary of the 4,661 public comments posted to the regulations.gov docket as of May 12. Of those comments, 98% expressed support for FEMA. By the close of the comment period on May 15, more than 13,000 comments had been submitted.

The post ASFPM Submits Recommendations to Strengthen FEMA first appeared on Association of State Floodplain Managers.

The letter explains that hazard mitigation — whether pre- or post-disaster — is the most cost-effective way to protect lives, property, and the federal budget. These programs reduce repetitive losses, improve public safety, and offer communities tools to become more resilient in the face of increasing natural disasters. ASFPM and the coalition of non-profit, private sector, and academic organizations emphasized that curtailing mitigation programs now would reverse decades of bipartisan progress and leave the nation more vulnerable.

“Investments in hazard mitigation programs make communities more resilient and can substantially reduce the economic costs of disasters,” the letter stated.  “As noted, numerous studies, including those by the U.S. National Institute of Building Sciences and the U.S. Chamber of Commerce confirm that every dollar spent on hazard mitigation can yield up to $13 in future savings. These aren’t just savings in the abstract — they represent homes that remain standing, businesses that remain open, communities that survive, and local governments that can recover more quickly and without financial collapse.”

Read the full letter

The post ASFPM Leads Coalition Urging Continued Support for FEMA Mitigation Programs first appeared on Association of State Floodplain Managers.

In the wake of Hurricanes Helene and Milton, ASFPM has submitted letters to House and Senate Appropriations Committee leadership detailing two sets of policy recommendations: immediate actions needed in a disaster supplemental to aid affected communities, and strategic long-term measures to strengthen nationwide flood resilience.

Estimates for the combined damages from Helene and Milton range to well upwards of $100 billion, ranking them among the costliest disasters in US history. The annual cost of flood events has roughly doubled each decade since the 1980s, now averaging over $40 billion/year. In the letters, ASFPM urged Congress to take concrete steps to break the cycle of damage-repair-damage and truly make the nation more resilient to the threat of flooding — reducing total damages and the burgeoning costs to taxpayers when the next flood occurs.

See the 15 recommendations put forth by the association.

The post ASFPM Policy Recommendations for Post-Hurricane Recovery first appeared on Association of State Floodplain Managers.

As disasters like Hurricanes Helene and Milton become increasingly common and destructive, it is more critical than ever to reduce administrative burden and streamline how state and local governments manage recovery funding provided by the Federal Emergency Management Agency (FEMA). This legislation accomplishes that goal, making it easier to manage and track disaster grants, including providing oversight of waste, fraud, and abuse. The bill’s broad, bipartisan support is a testament to the transformative impact it will have on efforts to support long-term recovery and mitigation — all without providing new funding or establishing a new program.

Read the letter

Disaster Assistance Simplification Act

In another sign-on letter just days later, ASFPM joined 17 other organizations to support passage of the Disaster Assistance Simplification Act. The bill requires FEMA to consolidate federal grant applications for disaster relief for disaster survivors into one centralized and universal application, relieving survivors from the burden of multiple long and strenuous application processes. The bipartisan bill passed the Senate unanimously in July 2023.

Read the letter

The post ASFPM Urges Support for Disaster Management Costs Modernization Act 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

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