National Flood Insurance Program

Community Rating System

Addendum to the 

2017 CRS Coordinator’s Manual

2021
Addendum to the 2017 CRS Coordinator’s Manual A-ii Edition: 2021

CONTENTS

Page

Foreword .................................................................................................................. A-1 

What Becomes Effective in 2021............................................................................... A-2 

How to Use the 2021 Addendum .............................................................................. A-4 

Section 116.a, Natural Floodplain Functions ................................................................. A-5 

Summary .................................................................................................................. A-5 

Revised Subsection on Threatened and Endangered Species................................... A-5 

Section 211 ................................................................................................................ A-10

Summary ................................................................................................................ A-10

New Prerequisite for Class 9.................................................................................... A-10 

New Prerequisite for Class 8.................................................................................... A-11 

Updated Prerequisite for Class 6 ............................................................................. A-11 

Clarifications, Updates, and Corrections................................................................. A-12 

Section 230, Verification............................................................................................... A-14 

Summary ................................................................................................................ A-14 

Updates and Clarifications....................................................................................... A-14 

Section 301, Public Information ................................................................................... A-15 

Summary ................................................................................................................ A-15 

Expanded Guidance on Construction Certificates................................................... A-15 

Related Updates and Corrections............................................................................ A-25 

Section 310, Elevation Certificates............................................................................... A-26 

Summary ................................................................................................................ A-26 

Revision of Activity 310............................................................................................ A-27 

Revised Approach to Elevation and Other Certificates........................................... A-29 

Related Updates and Corrections............................................................................ A-33 

Activity 370 (Flood Insurance Promotion) ................................................................... A-34 

Summary ................................................................................................................ A-34 

Increased Credit for a Flood Insurance Coverage Plan 

 and for Technical Assistance.............................................................................. A-36 

New Credit for Flood Insurance Brochures, Meetings, Continuing Education........ A-37 

Section 403, Impact Adjustment Map.......................................................................... A-41 

Correction ................................................................................................................ A-41 

Section 404, Sea Level Rise ........................................................................................... A-42 

Summary ................................................................................................................ A-42 

Updates to Sea Level Rise Projections..................................................................... A-42 
Addendum to the 2017 CRS Coordinator’s Manual A-iii Edition: 2021

Page

Activity 420 (Open Space Preservation)....................................................................... A-44 

Corrections............................................................................................................... A-44 

Activity 430 (Higher Regulatory Standards)................................................................. A-45 

Summary ................................................................................................................ A-45 

Discontinuation of state-mandated standards—SMS ............................................. A-45 

Related Updates and Corrections............................................................................ A-45 

Activity 450 (Stormwater Management) ..................................................................... A-46 

Summary ................................................................................................................ A-46 

Focus on Community Jurisdiction for Stormwater Management ........................... A-46 

Related Updates and Corrections............................................................................ A-48 

Section 501, The Repetitive Loss List............................................................................ A-50

Summary ................................................................................................................ A-50

Updates and Clarifications....................................................................................... A-50

Section 510, Floodplain Management Planning .......................................................... A-51 

Summary ................................................................................................................ A-51 

Credit Points and Opportunities Increase................................................................ A-51 

Species Assessments Qualify for Natural Functions Plan ....................................... A-52 

New Credit for a Substantial Damage Management Plan....................................... A-54 

Related Updates and Clarifications.......................................................................... A-61

Activity 610 (Flood Warning and Response)................................................................ A-62 

Summary ................................................................................................................ A-62 

Updates and Clarifications....................................................................................... A-62 

Cover photo courtesy of John Kinley
Addendum to the 2017 CRS Coordinator’s Manual A-1 Edition: 2021 

FOREWORD

The Community Rating System (CRS) is a national program developed by the Federal 

Emergency Management Agency (FEMA). The CRS Coordinator’s Manual is the 

guidebook for the CRS. The Coordinator’s Manual spells out the credits and credit 

criteria for community activities and programs that go above and beyond the minimum 

requirements for participation in FEMA’s National Flood Insurance Program. The 

Coordinator’s Manual explains how the CRS operates, how credits are calculated, and 

what documentation is required, and also acts as guidance for communities in

enhancing their flood loss reduction and resource protection activities.

From time to time, the Coordinator’s Manual is revised, to respond to improvements in 

floodplain management and insurance practice, advances in technology, input from 

communities and other program stakeholders, and other factors. These changes ensure 

that the CRS continues to encourage, support, and recognize communities for ongoing 

efforts to minimize flood losses and protect floodplain resources. Revisions normally 

take place every three years and are issued in the form of a new edition of the 

Coordinator’s Manual. 

This Addendum to the 2017 CRS Coordinator’s Manual is being issued by FEMA in lieu of 

producing a fully revised edition at this time. The Addendum, effective January 1, 2021, 

accompanies and becomes part of the 2017 edition of the Coordinator’s Manual. With 

the issuance of this Addendum, FEMA incorporates into the existing CRS guidance some 

material that officially changes, adds to, or clarifies the CRS program. This includes new 

prerequisites for advancing in CRS class as well as new opportunities for communities to 

earn CRS credit for protecting threatened and endangered species, mitigating 

substantial damage, and promoting flood insurance. 

The current Coordinator’s Manual, issued in 2017, accompanied by this Addendum, will 

remain in effect until a new edition is released. Therefore, the expiration date on the 

2017 Coordinator’s Manual can be disregarded. Both documents can be downloaded 

from the FEMA website.
Addendum to the 2017 CRS Coordinator’s Manual A-2 Edition: 2021 

What Becomes Effective in 2021

The most significant changes taking place with the release of this Addendum are four 

new opportunities for communities to earn CRS credit, and two new prerequisites—one 

for attaining CRS Class 9 and one for Class 8.

Credit Opportunities

• Under Activity 370 (Flood Insurance Promotion), the credit for a flood 

insurance coverage plan (element CP) is increased, as is that for providing 

technical assistance (element TA). Three new elements are introduced, 

providing credit for distributing flood insurance information (element 

FIB), for holding insurance-related town hall meetings (element FIM), and 

for a state requirement for continuing education for flood insurance 

agents (element SCE). 

• Under Activity 510 (Floodplain Management Planning), credit is made 

available for developing a floodplain species assessment in addition to, or 

as an alternative to, a natural functions plan (element NFP).

• A new creditable element is added under Activity 510 (Floodplain 

Management Planning) for communities that develop a plan for managing

substantial damage properties within their jurisdictions (element SDP). 

• Under Activity 610 (Flood Warning and Response), communities can 

receive credit for incorporating into their flood response operations plans 

specific measures for implementing substantial damage assessments 

after a flood (elements FRO2 and FRO5). 

Class Prerequisites

• As a prerequisite to achieving CRS Class 9, communities must develop a 

plan for managing floodplain-related construction certificates (including 

Elevation Certificates) within their communities and must maintain each 

year a 90% accuracy rate for those construction certificates.

• As a prerequisite for achieving CRS Class 8, communities must adopt and 

enforce at least one foot of freeboard for residential buildings in all 

numbered zones of the Special Flood Hazard Area (SFHA).
Addendum to the 2017 CRS Coordinator’s Manual A-3 Edition: 2021 

Clarifications

• With the addition of construction certificate management procedures 

(element CCMP) as a prerequisite to achieving CRS Class 9, the 

background information and discussion about Elevation Certificates in 

Section 300 and Section 310 have been re-organized. Although some new 

material has been added, most of what appears in the Section 300 entry, 

below, is not new but previously appeared in the Coordinator’s Manual in 

Section 310 instead of Section 300. Clarifications have been added to help 

communities develop a plan for managing floodplain-related construction 

certificates, and to explain that a community must maintain a 90% 

accuracy rate for its construction certificates every year.

• The CRS approach to crediting stormwater management regulations 

(element SMR) and watershed master plans (element WMP) under 

Activity 450 (Stormwater Management) is being modified with this 

Addendum. Beginning in 2021, the CRS focus is shifting from watershedwide management to a focus on managing the area within the 

community’s jurisdiction, i.e., what the community itself has authority to 

manage. This is reflected in the entries below by some changes in 

terminology and by modifications to the impact adjustments for elements 

SMR and WMP.

• Some typographical errors and confusing language have been corrected.
Addendum to the 2017 CRS Coordinator’s Manual A-4 Edition: 2021 

How to Use the 2021 Addendum 

to the 2017 CRS Coordinator’s Manual 

This Addendum material is presented in an order that corresponds to the 2017 

Coordinator’s Manual. Only those sections of the Coordinator’s Manual that are being 

changed appear in this Addendum. Each section begins with a short summary of the 

changes for that section. This is followed by a series of bulleted entries that identify the 

section or subsection and page number in the 2017 Coordinator’s Manual at which the 

change is to be incorporated. Significant changes in each section are listed first, 

followed by more minor corrections, if any, most of which are needed to make other 

parts of the Coordinator’s Manual consistent with the new language (such as renumbering where a new subsection has been inserted, or a implementing a change in 

terminology). Those portions of the 2017 Coordinator’s Manual that are not included in 

this Addendum remain unchanged. The Index and Appendices have not been updated.

For the convenience of communities, the new inserts and the replacement language are 

presented mostly as one or more full paragraphs, rather than as word-by-word changes. 

This makes it possible for the community to more easily incorporate the new material 

into whatever format it uses. 
Addendum to the 2017 CRS Coordinator’s Manual A-5 Edition: 2021 

Addendum to 

Section 116 of the CRS Coordinator’s Manual, 2017 Edition

Summary

The discussion in Section 116 about the importance of protecting natural floodplain 

functions is expanded to place more emphasis on threatened and endangered species. 

Some new paragraphs are added and some of the rest has been re-organized slightly. 

For simplicity, the entire subsection Section 116.a is replaced with the language below. 

There are no changes to Section 116.b or 116.c. 

Revised Subsection Focuses on 

Threatened and Endangered Species

 On page 110-12, the entire subsection 116.a is replaced with this revised material: 

116.a. Natural Floodplain Functions and 

 Threatened and Endangered Species 

Floodplains in riverine and coastal areas perform natural functions that cannot be replicated 

elsewhere. The CRS provides special credit for community activities that protect and/or 

restore natural floodplain functions, even though some of the activities may not directly 

reduce flood losses to insurable buildings. There are many reasons to protect floodplains in 

their natural state.

When kept open and free of development, floodplains provide the necessary flood water 

conveyance and flood water storage needed by a river or coastal system. When a floodplain 

is allowed to perform its natural function, flood velocities and peak flows are reduced 

downstream. Natural floodplains reduce wind and wave impacts and their vegetation 

stabilizes soils during flooding.

Floodplains in their natural state provide many beneficial functions beyond flood reduction. 

Water quality is improved in areas where natural cover acts as a filter for runoff and 

overbank flows; sediment loads and impurities are also minimized. Natural floodplains 

moderate water temperature, reducing the possibility of adverse impacts on aquatic plants 

and animals.
Addendum to the 2017 CRS Coordinator’s Manual A-6 Edition: 2021 

Floodplains can act as recharge areas for 

groundwater and reduce the frequency 

and duration of low flows of surface 

water. Floodplains and coastal areas provide habitat—especially breeding and 

feeding areas—for diverse species of 

flora and fauna, some of which cannot 

live anywhere else, and some of which 

have been identified as needing special 

protection because their numbers are 

dwindling. Ways in which the CRS 

supports the protection of threatened and 

endangered species and their critical 

habitat are discussed at the end of this 

subsection.

Credit for Protecting Natural 

Floodplain Functions

The CRS encourages state, local and 

private programs and projects that 

preserve or restore the natural state of 

floodplains and protect these functions. 

The CRS also encourages communities 

to coordinate their flood loss reduction 

programs with other public and private 

activities that preserve and protect 

natural and beneficial floodplain 

functions. Credits for doing this are found in the following activities:

• Activity 320 (Map Information Service)—Credits advising people about areas that 

should be protected because of their natural floodplain functions.

• Activity 330 (Outreach Projects)—Credit is provided for outreach projects that 

include descriptions of the natural functions of the community’s floodplains. 

• Activity 350 (Flood Protection Information)—Credit points are available for a 

website that provides detailed information about local areas that should be 

protected for their natural floodplain functions and how they can be protected. 

• Activity 420 (Open Space Preservation)—Extra credit is provided for open space 

areas that are preserved in their natural state; have been restored to a condition 

approximating their pre-development natural state; or have been designated as 

worthy of preservation for their natural benefits, such as being designated in a 

habitat conservation plan.

• Activity 430 (Higher Regulatory Standards)—Regulations that protect natural 

areas during development or that protect water quality are credited.

Some Natural Functions of Floodplains

WATER RESOURCES

 Natural Flood and Erosion Control

- Provide flood storage and conveyance

- Reduce flood velocities

- Reduce peak flows

- Reduce sedimentation

 Water Quality Maintenance

- Filter nutrients and impurities from runoff

- Process organic wastes

- Moderate temperature fluctuations

 Groundwater Recharge

- Promote infiltration and aquifer recharge

- Reduce frequency and duration of low surface flows

BIOLOGICAL RESOURCES

 Biological Productivity

- Rich alluvial soils promote vegetative growth

- Maintain biodiversity

- Maintain integrity of ecosystems

 Fish and Wildlife Habitats

- Provide breeding and feeding grounds

- Create and enhance waterfowl habitat

- Protect habitats for rare and endangered species

− A Unified National Program for Floodplain Management 

FEMA-248 (1994)
Addendum to the 2017 CRS Coordinator’s Manual A-7 Edition: 2021 

• Activity 440 (Flood Data Maintenance)—Adding layers to the community’s 

geographic information system (GIS) with natural floodplain functions (e.g., 

wetlands, designated riparian habitat, flood water storage areas) is credited.

• Activity 450 (Stormwater Management)—Erosion and sediment control, water 

quality, and low-impact development techniques minimize the impacts of new 

development. These measures are credited, along with regulations that require the 

maintenance of natural flow regimes.

• Activity 510 (Floodplain Management Planning)—Extra credit is provided for 

plans that address the natural resources of floodplains and recommend ways to 

protect them.

• Activities 520 (Acquisition and Relocation), 530 (Flood Protection), and 540 

(Drainage System Maintenance)—Measures such as capital improvement programs 

and drainage improvement projects can reduce flood losses. No such programs or 

projects can be credited unless a thorough environmental review is conducted and 

documented.

A community that wants to explore what it can do under the CRS activities listed above 

could start by preparing a natural functions plan (described and credited under Activity 510 

(Floodplain Management Planning)). That will help to identify the existing and desired

natural functions and to generate recommendations for how to preserve and increase those 

functions. 

Credit for Protecting Threatened and Endangered Species

As noted in the previous section, floodplains and coastal areas can serve as habitat for many 

animals and plants. One group of animals and plants deserving special protection are threatened and endangered species. Because of their declining numbers, these species have been 

listed by the U.S. Fish & Wildlife Service or the National Marine Fisheries Service as 

needing protection under the provisions of the Endangered Species Act. They “are of 

esthetic, ecological, educational, historical, recreational, and scientific value to the Nation 

and its people” (Endangered Species Act of 1973 (16 U.S.C. § 1531 et seq.)). In addition, 

many states maintain their own lists of species that are considered threatened, endangered, 

or “of concern.”

More and more, floodplain managers are recognizing the close relationship between 

protection of flood-prone property and protection of threatened and endangered species. 

Many good floodplain management practices, such as keeping wetlands, stream banks, and 

beaches in their undisturbed natural condition, also support the protection of habitats that 

are essential for the survival of many threatened and endangered species.

Supporting the conservation and recovery of threatened and endangered species is a worthy 

goal in itself and also is called for under the Endangered Species Act. Section 7 of the Act 

gives all federal agencies a responsibility to use their authorities in support of the Act. 

Many states and communities have made protection of threatened and endangered species 

one of their own priorities.
Addendum to the 2017 CRS Coordinator’s Manual A-8 Edition: 2021 

The CRS encourages and credits actions that further the conservation and recovery of 

threatened and endangered species under the following activities.

• Activity 320 (Map Information Service)‒‒This activity credits providing information about 

areas that have been designated as critical habitat, can serve as breeding grounds, or 

otherwise support threatened and endangered species. 

• Activity 330 (Outreach Projects)‒‒Outreach projects and programs for public information 

receive credit for messages on protecting threatened and endangered species that live in the 

area, such as explaining fishing restrictions or keeping pets on leashes. 

• Activity 350 (Flood Protection Information)‒‒Having materials on protecting local species 

in the local public library and on the community’s website is credited. 

• Activity 420 (Open Space Preservation)‒‒Preserving open space in the floodplain helps 

many species. Bonus credit is provided if the open space is in its natural state and even 

more credit if it has been designated as critical habitat for a threatened or endangered 

species. Other credits that help species include preserving open space on eroding 

shorelines, offering incentives to developers to keep the floodplain open, zoning floodprone areas for large lot sizes to preserve low density uses, and preserving stream banks 

and shorelines in their natural state.

• Activity 430 (Higher Regulatory Standards)‒‒As an alternative to keeping floodplains 

open, this activity credits regulations that protect habitat when floodplains are developed. 

These include prohibiting filling in the floodplain and regulating development in areas 

subject to coastal erosion (which often are essential areas for many species, such as shore 

birds and sea turtles). 

• Activity 440 (Flood Data Maintenance)‒‒Including maps of the range and habitat for 

threatened and endangered species in the community’s GIS is credited because it provides 

important information to GIS users, such as permit officials and highway planners, who 

need to take protection of these areas into account. 

• Activity 450 (Stormwater Management)‒‒Protecting and improving water quality and 

maintaining more consistent flows over time help many aquatic species and are credited by 

regulations that require new developments to use low impact development techniques, 

require control of the volume of runoff, or develop an overall plan for the watershed that 

addresses threatened and endangered species. 

• Activity 510 (Floodplain Management Planning)‒‒In addition to crediting inclusion of 

natural floodplain functions in a floodplain management or hazard mitigation plan, this 

activity has a separate element for plans that address protecting natural floodplain 

functions and a new credit for preparing and implementing a floodplain species 

assessment. 
Addendum to the 2017 CRS Coordinator’s Manual A-9 Edition: 2021 

• Activities 520 (Acquisition and Relocation) and 530 (Flood Protection)‒‒The prerequisite 

environmental and historic preservation certification process can identify opportunities for 

reuse of the sites to support the conservation and recovery of threatened and endangered

species.

• Activity 540 (Drainage System Maintenance)‒‒This activity encourages communities to 

regulate dumping in streams and to develop habitat-friendly approaches to clearing debris 

in drainageways. 

A community that wants to explore what it can do under these activities could start with 

reviewing CRS Credit for Habitat Protection and preparing a Floodplain Species 

Assessment, which is credited under Activity 510 (Floodplain Management Planning). More 

information on these and on protecting threatened and endangered species and habitat in 

general can be found in Section 514. 
Addendum to the 2017 CRS Coordinator’s Manual A-10 Edition: 2021 

Addendum to

Section 211 of the CRS Coordinator’s Manual, 2017 Edition

Summary

A new prerequisite to achieving Class 9 is introduced, requiring communities to develop 

a plan for managing floodplain-related construction certificates (including an annual 

90% accuracy rate). A new prerequisite for achieving Class 8 is introduced, requiring 

communities to adopt and enforce freeboard for residential buildings in their SFHAs. 

The earlier Class 6 prerequisite—meeting the Class 9 prerequisites—is changed to 

require all Class 6 communities to meet the Class 8 prerequisites, including the 

freeboard requirement.

New Prerequisite for Class 9

 On page 210-1, under the Class 9 prerequisites, subsection (3) is replaced with the 

following:

(3) The community must 

(a) Maintain all required floodplain-related construction certificates as described in 

Section 301.b for all buildings constructed, substantially improved, and/or 

reconstructed due to substantial damage in the Special Flood Hazard Area (SHFA) 

after the community applies for CRS credit.

(b) Achieve 90% accuracy on its floodplain-related construction certificates during its 

annual review. This is explained in Section 301.e. 

(c) Receive credit for construction certificate management procedures (element CCMP) 

under Activity 310 (Elevation Certificates). 

 On page 210-2, under the Class 9 prerequisites, the first sentence of subsection (5) is 

replaced with this sentence:

The community must maintain in force flood insurance policies for insurable buildings 

owned by the community and located in the SFHA shown on the community’s Flood 

Insurance Rate Map (FIRM). 
Addendum to the 2017 CRS Coordinator’s Manual A-11 Edition: 2021 

New Prerequisite for Class 8

 On page 210-4, a new subsection is inserted:

211.b. Class 8 Prerequisites 

(1) The community must meet all the Class 9 prerequisites.

(2) The community must adopt and enforce at least a 1-foot freeboard requirement 

(including machinery or equipment) for all residential buildings constructed, 

substantially improved, and/or reconstructed due to substantial damage throughout its 

SFHA where base flood elevations have been determined on its currently effective

FIRM or in its Flood Insurance Study (FIS), except those areas that receive open space 

credit under Activity 420 (Open Space Preservation).

The Class 8 prerequisite can be met through the enforcement of local ordinances or building 

codes, and/or state building codes, provided the freeboard standard applies to all residential 

buildings, whether single-family, multi-family, or manufactured. This includes the 

replacement of manufactured homes in pre-FIRM manufactured home parks. 

The ordinance or building code must require that machinery or equipment be elevated to at 

least 1 foot above the base flood elevation for buildings newly constructed, substantially 

improved, and/or reconstructed due to substantial damage. This requirement includes 

machinery and equipment placed within attached garages and/or within enclosures below 

elevated buildings, with the exception of utility meters and equipment specifically designed 

to withstand inundation according to the standards of the International Residential Codes 

and the NFIP. The Class 8 freeboard prerequisite will be met provided that attached garages 

and enclosures below elevated buildings meet the minimum requirements of the NFIP 

(elevated to the base flood elevation or having proper openings). 

Communities that enforce an adopted freeboard standard that meets the Class 8 prerequisite 

will be provided with freeboard (element FRB) credit under Activity 430 (Higher 

Regulatory Standards). Credit will be evaluated at the next CRS verification visit or next 

modification.

Updated Prerequisite for Class 6

 Under Class 6 Prerequisites on page 210-4, subsection (1) replaced with this:

(1) The community must meet all the Class 8 prerequisites. 
Addendum to the 2017 CRS Coordinator’s Manual A-12 Edition: 2021 

Clarifications, Updates, and Corrections

 Under Class 6 Prerequisites on page 210-4, subsection 211.b is re-numbered to read:

211.c. Class 6 Prerequisites 

 Under Class 4 Prerequisites on page 210-4, subsection 211.c is re-numbered to read:

211.d. Class 4 Prerequisites 

 Under Class 4 Prerequisites where it continues on page 210-5, two typographical 

errors are corrected in subsection (3)(a)(ii) and in (3)(b). The replacement language

reads: 

(ii) The community must receive at least 700 points (after the impact adjustment) 

under the other elements of Activity 430 and under Sections 422.a, f, and g under 

Activity 420 (Open Space Preservation).

(b) Activity 450 (Stormwater Management)—The community must receive the following 

credits for its watershed management plan(s) (WMP) under Section 452.b:

 Under Class 4 Prerequisites where it continues on page 210-5, the fifth bullet of

subsection (4) is clarified to read:

○ 450—Managing the volume of stormwater runoff (SMR, DS bonus credit),

 Under Class 1 Prerequisites on page 210-6, subsection 211.d is re-numbered to read:

211.e. Class 1 Prerequisites 

 Under Class 1 Prerequisites where it continues on page 210-7, subsection 4(a)(i) is 

replaced with the following to clarify the scoring:

(i) The community must be enforcing regulations that discourage development in the 

floodplain. This is demonstrated by receiving a combined total of at least 150 points 

(before the impact adjustment) from open space incentives (OSI) in Section 422.e and 

development limitations (DL) in Section 432.a.
Addendum to the 2017 CRS Coordinator’s Manual A-13 Edition: 2021 

 Under 214.a. Modification Criteria where it continues on page 210-14, a new 

subsection (7) is inserted, and the existing subsection is re-labelled (8). The 

replacement segment for the top of page 210-14 is this:

(4) If a community is modifying an activity previously applied for, its submittal must 

include documentation for both the new elements of the activity and those that were 

previously credited, if they are still being implemented. 

(5) The ISO/CRS Specialist verifies only the activity(ies) being modified and reviews the 

rest at the next cycle verification visit. There are two exceptions to this, as noted under 

(6) and (7), below.

(6) The ISO/CRS Specialist will automatically update the community’s credit points for

(a) The community’s BCEGS classification (a Class 6 and Class 4 prerequisite and 

credited in Section 432(h));

(b) The community’s credit for the state dam safety credit (Section 632.a); and

(c) The county growth adjustment (Section 710). If the growth adjustment is changed, 

the total points for all affected activities in the 400 series will reflect the new factor.

(d) If the community’s repetitive loss category has changed since the previous cycle 

verification, the community must comply with Section 502.a, as applicable.

(7) A community that submits a modification that would result in a class change must meet 

the pertinent class prerequisites in effect at the time of the modification, as listed in the 

Coordinator’s Manual and Addendum in effect at the time or the modification request. 

These prerequisites are in addition to the requirement for the additional credit points 

needed for a class increase.

(8) The community’s entire program is verified with a verification visit under the following 

circumstances: 

(a) If the modification will result in a two-class improvement, or 

(b) If the Coordinator’s Manual has substantially changed most of the rest of the 

community’s credits. 

In these situations, the verification visit counts as a cycle verification visit and the 

community’s cycle schedule starts over.
Addendum to the 2017 CRS Coordinator’s Manual A-14 Edition: 2021 

Addendum to

Section 230 of the CRS Coordinator’s Manual, 2017 Edition

Summary

The revised procedures for collecting and reviewing construction certificates for CRS 

credit in Section 301 and under Activity 310 result in a slight change in the process 

followed by the CRS for verifying a community’s credit. Accordingly, two changes are 

introduced in Section 230, Verification. 

Updates and Clarifications

 Under Preparation on pages 230-7 and 230-8, the language is revised to reflect the 

new procedure for reviewing construction certificates. The two paragraphs are 

replaced with this single paragraph:

Preparation 

The documentation that is needed for the verification visit is listed in the “Documentation

Provided by the Community” section for each element or activity. The ISO/CRS Specialist

will send a list of typical documentation with the meeting confirmation letter. Other 

documentation is collected during the visit and either reviewed then or taken by the 

ISO/CRS Specialist to review later.

 Under Verification Thresholds on page 230-9, the list of bullets is revised to reflect 

the new procedure for reviewing construction certificates. The three bullets are 

replaced with these two:

• Floodplain and stormwater management regulations in the 400 series: 80%; and 

• All others: 50%.
Addendum to the 2017 CRS Coordinator’s Manual A-15 Edition: 2021 

Addendum to

Section 301 of the CRS Coordinator’s Manual, 2017 Edition

Summary

To provide better guidance for communities in managing the various construction 

certificates that are needed to mitigate flood damage and also receive CRS credit, a new 

Section 301 is created by relocating guidance from Sections 311.a, b, and c of the 2017 

Coordinator’s Manual, and revising and expanding that guidance. The figures in this new 

section have been relocated from the 2017 edition of Section 311 and renumbered. 

Expanded Guidance on Construction Certificates

 On page 300-4, a new Section 301 is inserted: 

301 Construction Certificate Requirements 

The National Flood Insurance Program (NFIP) requires that participating communities 

maintain a record of the elevation of the lowest floor of any new building or substantial 

improvement built in the SFHA (see the Code of Federal Regulations (44 CFR

§60.3(b)(5)(iii))). In 44 CFR §59.22(a)(9)(iii), the NFIP also requires that communities 

make their elevation and related building information available for public inspection and 

flood insurance rating. 

Participation in the CRS requires that, in addition to the NFIP requirements, communities 

obtain other floodplain-related construction certifications and ensure that they are filled out 

completely and correctly. This should be done as soon as construction is complete, 

preferably by someone who is familiar with the NFIP, and before the certificate of 

occupancy or certificate of use is issued. It is vital to get accurate certifications filed while 

the community still has authority to get corrections made. 

Accurate and readily available data on a building’s flood zone, elevation, and other 

construction information are essential to insurance agents for processing an application for 

a flood insurance policy. Such information not only contributes to accurate insurance rating

but also helps determine whether buildings are compliant with NFIP requirements. 

Therefore, a prerequisite for participation in the CRS is that communities obtain, review, 

correct, and maintain all these certificates; make them available to the public; and have 

written procedures for this process, as described in Section 310.
Addendum to the 2017 CRS Coordinator’s Manual A-16 Edition: 2021 

301.a. CRS Participation Requirement

The community is required to maintain “finished-construction” Elevation Certificates and 

all other required floodplain-related construction certificates (see Section 301.b) on all 

buildings in the community’s Special Flood Hazard Area (SFHA) that are constructed, 

substantially improved, and/or reconstructed due to substantial damage after the community 

applies for CRS credit. Communities must review the certificates and make sure at least 

90% of them are correct according to the verification process. Written procedures for the 

management of construction certificates (see Activity 310), are required as well, and must

meet the credit criteria in Section 312.a.

Those few NFIP communities that have no SFHA may still receive credit for this activity 

since credit is for having written procedures in place on how to handle construction 

certificates once they are obtained from property owners or developers. Communities 

should remember, however, that a CRS community with no SFHA that either subsequently

receives a FIRM from FEMA that delineates areas of SFHA or annexes an area with an 

SFHA must begin maintaining construction certificates on the date of the FIRM or 

annexation or it will lose its credit.

Some communities require floodplain-related construction certificates for new buildings in 

flood-prone areas that are outside the SFHA but are regulated by the community. The CRS 

encourages this as a good floodplain management practice. However, because the 

certificates are not used in flood insurance rating, there is no requirement under this activity 

that certificates for buildings outside the SFHA be maintained or submitted for review. 

The four specific participation requirements are these:

(1) The community must maintain the completed construction certificates listed in Section 

301.b, Required Floodplain-related Construction Certificates, for all insurable 

buildings constructed, substantially improved, and/or reconstructed due to substantial 

damage in the SFHA every year and must supply these certificates annually as 

prescribed by the CRS (see Section 301.e, Construction Certificate Verification). 

“Buildings” are defined in Section 302.a.

(2) The community must review all its required construction certificates to ensure that they 

are complete and that the information is correct. This is described in in Section 301.c, 

Construction Certificate Checklists and Section 301.d, Getting Correct Construction 

Certificates. At least 90% of the certificates must be correct at each annual review in 

order for the community to remain in the CRS.

(3) The community must make copies of construction certificates readily available to 

anyone upon request. All participating communities must be able to retrieve the 

certificates, including those from projects whose permit files may have been archived 

or discarded. 

(4) The community must have written procedures for the management of its floodplainrelated construction certificates that includes a description for how the community 

implements requirements (1), (2), and (3), and following the criteria listed in 

Section 312.a.
Addendum to the 2017 CRS Coordinator’s Manual A-17 Edition: 2021 

301.b. Required Floodplain-related Construction Certificates 

Under this activity a community is REQUIRED TO EMPLOY ALL FIVE OF THE FOLLOWING where 

appropriate. For CRS purposes, therefore, “construction certificates” means all required 

floodplain-related certificates listed in this sub-section that apply to the community’s 

situation (e.g., inland communities will not have use for a V zone design certification). 

• All new buildings or substantial improvement built in the SFHA must have a record 

showing that the lowest floor is at or above the base flood elevation, using the 

FEMA Elevation Certificate (FEMA Form 086-0-33). 

• Floodproofed non-residential buildings require FEMA’s Floodproofing Certificate

for Non-Residential Structures (FEMA Form 086-0-34). A separate Elevation 

Certificate is not needed for these buildings. The 2015 Floodproofing Certificate 

requires elevations based on finished construction.

• A V Zone design certificate is required for all buildings constructed, substantially 

improved, and/or reconstructed due to substantial damage in coastal high hazard 

areas (V Zones and coastal A Zones, where credited) after the community’s first 

verification visit under the 2013 edition of the Coordinator’s Manual. 

• A sample V Zone design certificate is shown in Figure 301-1. Communities with 

alternative forms or certifications may submit them to their ISO/CRS Specialists to 

see if they meet this activity’s criteria.

• Communities that have received a residential basement floodproofing exception must 

use FEMA’s Residential Basement Floodproofing Certificate (FEMA Form 086-0-

24) where applicable.

• When engineered flood openings are installed in the foundation of a building, an 

engineered opening certification must be attached to the Elevation Certificate. The 

International Code Council® Evaluation Service (ICC-ES) produces reports for engineered 

flood openings, and individual certifications also can be done provided that they cover all 

required items. Engineered opening certifications are required for all buildings 

constructed, substantially improved, or reconstructed due to substantial damage, since the 

community’s first verification visit under the 2013 Coordinator’s Manual. 

Copies of the FEMA Elevation Certificate and the FEMA Floodproofing Certificate can be 

downloaded from FEMA’s website. Instructions are included with the forms.

For new construction, only the current FEMA forms are acceptable. A community may 

receive credit by transferring data from other forms onto a FEMA certificate.

NOTE: The most recent Elevation Certificate form was published by FEMA on 

February 21, 2020 (expiration date November 30, 2022). Even though it is unchanged from

the previous one, this newer form must be used by anyone who signs and dates the form on 

or after February 21, 2020. 
Addendum to the 2017 CRS Coordinator’s Manual A-18 Edition: 2021 

Figure 301-1. A sample V Zone design certificate (from FEMA’s Home Builder’s Guide to 

Coastal Construction, Technical Fact Sheet No. 1.5). 

V ZONE DESIGN CERTIFICATE

Name Policy Number (Insurance Co. Use) __ ______

Building Address of Other Description ______

Permit No. ______ ____City _State _____Zip Code ______

SECTION I: Flood Insurance Rate Map (FIRM) Information 

Community No. Panel No. Suffix FIRM Date FIRM Zone(s) 

SECTION II: Elevation Information Used for Design 

[NOTE: This section documents the elevations/depths used or specified in the design – it does not document surveyed elevations 

and is not equivalent to the as-built elevations required to be submitted during or after construction.] 

1. FIRM Base Flood Elevation (BFE) ....................................................................................................................... ______ feet* 

2. Community’s Design Flood Elevation (DFE) .........................................................................................................______ feet* 

3. Elevation of the Bottom of Lowest Horizontal Structure Member...........................................................................______ feet* 

4. Elevation of Lowest Adjacent Grade .....................................................................................................................______ feet* 

5. Depth of Anticipated Scour/Erosion used for Foundation Design .......................................................................... ______ feet 

6. Embedment Depth of Pilings of Foundation Below Lowest Adjacent Grade.......................................................... ______ feet 

 * Indicate elevation datum used in 1-4:  NGVD29  NAVD88  Other ______

SECTION III: V Zone Design Certification Statement 

I certify that: (1) I have developed or reviewed the structural design, plans, and specifications for construction of the abovereferenced building and (2) that the design and methods of construction specified to be used are in accordance with accepted 

standards of practice** for meeting the following provisions: 

• The bottom of the lowest horizontal structural member of the lowest floor (excluding piles and columns) is elevated to or above the BFE. 

• The pile and column foundation and structure attached thereto is anchored to resist flotation, collapse, and lateral movement due to the 

effects of the wind and water loads acting simultaneously on all building components. Water loading values used are those associated 

with the base flood***. Wind loading values used are those required by the applicable State or local building code. The potential for scour 

and erosion at the foundation has been anticipated for conditions associated with the base flood, including wave action. 

SECTION IV: Breakaway Wall Design Certification Statement

[NOTE. This section must be certified by a registered engineer or architect when breakaway walls are designed to have a resistance 

of more than 20 psf (0.96 kN/m2) determined using allowable stress design] 

I certify that: (1) I have developed or reviewed the structural design, plans, and specifications for construction of breakaway walls

to be constructed under the above-referenced building and (2) that the design and methods of construction specified to be used

are in accordance with accepted standards of practice** for meeting the following provisions:

• Breakaway wall collapse shall result from a water load less than that which would occur during the base flood***. 

• The elevated portion of the building and supporting foundation system shall not be subject to collapse, displacement, or other 

structural damage due to the effects of wind and water loads acting simultaneously on all building components (see Section III). 

SECTION V: Certification and Seal

This certification is to be signed and sealed by a registered professional engineer or architect authorized by law to certify 

structural designs. I certify the V Zone Design Certification Statement (Section III) and ________ the Breakaway Wall Design 

Certification Statement (Section IV, check if applicable).

Certifier’s Name License Number 

Title Company Name 

Address 

City State Zip Code 

Signature Date Telephone 

Note: The V Zone design certificate is not a substitute for the NFIP Elevation Certificate (see Fact Sheet No. 1.4, Lowest Floor Elevation), 

which is required to certify as-built elevations needed for flood insurance rating.
Addendum to the 2017 CRS Coordinator’s Manual A-19 Edition: 2021 

301.c. Construction Certificate Checklists 

As noted in Section 301.a, the community must review its required construction certificates 

to ensure that the information is correct and must meet a 90% accuracy threshold in doing 

so. The CRS Resource Specialist collects all certificates the community is required to 

submit and checks them for specific items. The CRS checklist for the 2006, 2009, 2012, 

2015 and 2019 Elevation Certificate forms is shown in Figure 301-2. The CRS Resource 

Specialist can provide a form with the checklist items highlighted as well as similar 

checklists for earlier versions of the FEMA forms. Checklists for the Floodproofing 

Certificate, V Zone design certificate, and the Residential Basement Floodproofing 

Certificate can be obtained from the ISO/CRS Specialist.

If any of the items on the checklist are not completed or are incorrect, that certificate will 

count against the 90% accuracy requirement as explained in Section 301.e.

Note that, although Item A6. of the instructions to the Elevation Certificate form requires 

photos of the structure, the photos are only required for purchasing flood insurance. Photos 

are not required for the community’s permit records nor are they required for CRS credit. 

However, a community that does have them is encouraged to submit them with its 

certificates because they can contribute to understanding the building’s construction. In 

addition, photos are encouraged and credited as part of the three inspections for regulations 

administration credit (element RA) in Section 432.q.

301.d. Getting Correct Construction Certificates 

It is the community’s responsibility to ensure that the construction certificates it maintains 

have been completed correctly. Certificates provided by surveyors must be proofread and 

corrected if errors or omissions are found. Although the surveyed elevations are likely to be 

correct, it is not unusual for surveyors to enter the wrong FIRM date or diagram number or 

to leave some entries blank in Section C of the Elevation Certificate form.

One way in which communities have improved the quality of their Elevation Certificates is 

by completing Sections A and B at the time of the permit application. The partially 

completed form then is given to the applicant or to the surveyor, who then can focus on 

completing the surveyed information in Section C. This has been shown to reduce many of 

the more common errors. 

For certificates with omitted or incorrect checklist items, the community has these options:

(1) For any inaccurate or incomplete information in Section C2 of an Elevation 

Certificate, the local official should request a new certificate. 

(2) If incomplete or inaccurate information is found in the other sections, the local official 

can do the following. As a general rule, and as law in some states, the local official 

should not mark up a signed and sealed form.

o The forms may be returned to the surveyor with instructions on what needs to 

be changed or corrected; 
Addendum to the 2017 CRS Coordinator’s Manual A-20 Edition: 2021 

SECTION A—PROPERTY INFORMATION

A2 and A3

 Complete street address or property description. In either case, the city, state, and 

 zip code must be listed.

A4 Building Use: must be filled in and accurately identifies the use of the building.

A6 Photographs: Photographs are not required for CRS credit. However, they are required 

for writing a flood insurance policy and they can be very helpful for compliance records.

A7 Building diagram number.

A8 a), b), and c) Enclosure and crawl space information for buildings that are 

diagram 6, 7, 8, or 9. 

A9 a), b), and c) Attached garage information. If there is no attached garage, enter “N/A” in 

all three spaces. If there is an attached garage and there are no openings, the correct 

entry is “zero,” even if the garage is above the BFE. 

A8 and 

A9 If the square footage of the crawlspace or garage is larger than the square inches of 

 the openings AND “(d) Engineered flood openings” is checked “yes,” then there must be 

 a certification by a registered design professional or a copy of the ICC Evaluation

 Service report. 

SECTION B—FLOOD INSURANCE RATE MAP (FIRM) INFORMATION 

B1 NFIP community name/community number. 

B4 Map AND panel number.

B5 Panel number and suffix.

B7 FIRM panel effective/revised date.

B8 Flood zone(s) in which the building is located.

B9 Base flood elevation(s).

B10 The source of the base flood elevation data or base flood depth entered in B9. 

B11 The elevation datum used for the base flood elevation in B9.

SECTION C—BUILDING ELEVATION INFORMATION (when a survey is required) 

C1 Basis for building elevations: Note: “Finished construction” must be checked unless the 

building is still under construction. The ISO/CRS Specialist will not review Elevation 

Certificates for buildings still under construction, unless requested to by the community. 

C2 Elevations. The vertical datum and datum used for entries a) through h) must be 

completed. Items a) through g) must have an entry. 

 Elevation items a), f), and g) must be recorded on every certificate. If an item does not 

apply, enter “N/A” in the fields where no data are being supplied. 

 Items b) and c) must be completed with an elevation if they are applicable and if that 

letter appears on the diagram on pages 7−9 of the instructions. 

 If there is an attached garage, an elevation must be entered for item d), otherwise the entry 

is “N/A.” If there is machinery and/or equipment that service the building, an elevation must 

be entered for item e), otherwise the entry is “N/A.”

Figure 301-2. CRS Checklist for the 2006, 2009, 2012, 2015, and 2019 

 FEMA Elevation Certificate forms.
Addendum to the 2017 CRS Coordinator’s Manual A-21 Edition: 2021 

SECTION D—CERTIFICATION BY A REGISTERED DESIGN PROFESSIONAL

Certifier’s name and license number 

Certifier’s signature

Date

If there is a signature and/or date in the box, there does not have to be a separate signature or 

date on the line. 

SECTION E—BUILDING ELEVATION INFORMATION (when a survey is not required in a Zone 

AO or a Zone A without a base flood elevation) 

E1 a) and b) Enter the difference between the top of the bottom floor and the highest and 

lowest adjacent grade.

E2 For Building Diagrams 6–-9 with openings, enter the difference between the top of the next 

higher floor and the highest adjacent grade.

E3 Enter the difference between the top of the garage slab and the highest adjacent grade.

E4 Enter the difference between the top of the platform for machinery or equipment and the 

highest adjacent grade.

Note: If Section E is used, then Sections F or G must be completed.

SECTION F—PROPERTY OWNER (OR OWNER’S REPRESENTATIVE) CERTIFICATION

This section is used if Section E is completed by the owner or owner’s representative. If used, this 

section must include the property owner’s or representative’s name in the first line and the signature in 

the third line.

SECTION G—COMMUNITY INFORMATION

If G1 or G2 is checked, then the first and third lines after G10 (the local official’s name and signature) 

must be completed. 

NOTE: If a local official authorized by law to complete an Elevation Certificate fills out ALL the 

information (including elevation data), then G8, G9, and the signature block must be completed. 

Figure 301-2 (cont.). CRS Checklist for the 2006, 2009, 2012, 2015, and 2019 

 FEMA Elevation Certificate forms.

o The local official can prepare a separate memo with the correct information 

and attach the memo to the form (see Figure 301-3). When the certificate is 

provided to an inquirer, the memo must be included with it; or 

o For Elevation Certificates, the local official can note the changes or 

corrections in Section G. 
Addendum to the 2017 CRS Coordinator’s Manual A-22 Edition: 2021 

Figure 301-3. An example of a cover sheet for a correction to an Elevation Certificate. Some 

communities use a correction form like this when an error or omission is found that can be 

corrected by the local official. It is stapled to the certificate that is made available to 

inquirers. Note that the community assumes responsibility for the accuracy of the changes it 

makes. This form must include the address of the building and be signed and dated. A copy 

may be obtained from the ISO/CRS Specialist. 
Addendum to the 2017 CRS Coordinator’s Manual A-23 Edition: 2021 

301.e. Construction Certificate Verification

Each year at its annual recertification date, a community must submit the following:

(1) A list of all permits (the “Permit List”) issued for new buildings constructed, 

substantially improved, and/or reconstructed due to substantial damage in the SFHA 

since the previous recertification due date (February 1, May 1, August 1, or October 

15) or since the date the community applied to the CRS, whichever is later. The list 

must include the address of each building; the use of each building (e.g., residential, 

non-residential, or other term used in Section A4 of the 

FEMA Elevation Certificate); FIRM zone (AE, A, VE, 

etc.); whether it is a new building, a substantial

improvement, or a reconstruction due to substantial 

damage; the date of the permit; and whether the permit is 

final. 

(2) Copies of all required construction certificates as 

described in Section 301.b for all new buildings, 

substantial improvements, and/or reconstructions due to 

substantial damage in the SFHA that have been collected 

since the previous recertification due date, or the date of 

the community’s initial application to the CRS, 

whichever is later. All certificates are to be submitted to 

the CRS Resource Specialist. 

(3) If the community is applying for or receiving credit for 

regulating areas outside the SFHA, it must let its CRS 

Resource Specialist know. The community will then be 

advised whether the list of permits and copies of 

certificates in (1) and (2), above, should include 

properties in those non-SFHA areas.

The Permit List and certificates can be provided in paper or digital format, although digital 

format is preferred. Communities are encouraged to scan paper certificates at 300 dpi 

grayscale (no color). The fillable pdf versions of the certificates are preferred, for easier 

processing. If the community maintains digital copies of building permit records, digital 

copies of the certificates should be separated from the rest of the file so that they can easily 

be collected to meet this requirement. Individual certificate files, identified by address, 

should be submitted if at all possible. The community may charge inquirers a reasonable fee 

to cover the cost of copying the certificates. 

For this credit, certificates are not needed for accessory structures; non-substantial 

improvements; or non-buildings such as fill, fences, swimming pools, cell towers, etc. Nor 

are certificates needed for properties outside the SFHA (except as noted in Section 

301.e(3), above). If certificates are needed to verify credit under another activity, they 

should be submitted with that activity’s documentation.

Elevation Certificates 

Completed by the 

Community

Elevation Certificates can be 

completed by a local official who is 

authorized by law or ordinance to 

administer the community’s 

floodplain management program, 

provided that the original surveyed

elevations in Section C were 

obtained by a registered design 

professional. 

A community can transfer data 

from a surveying project to the 

FEMA Elevation Certificate form if 

it can demonstrate that the source 

of the data was appropriate and if 

the source is described in 

Section G of the certificate.
Addendum to the 2017 CRS Coordinator’s Manual A-24 Edition: 2021 

NOTE: It is acceptable to show permits issued for buildings that do not yet have finishedconstruction certificates because construction has not been completed. It is also acceptable 

to have certificates for buildings that are not on the current Permit List because the permits 

were issued before the previous recertification’s due date. A community should ensure that

this is communicated to the CRS Resource Specialist. 

The CRS Resource Specialist should be notified if there have been no new buildings, 

substantial improvements, or reconstructions due to substantial damage in the SFHA since 

the last submittal. 

The CRS Resource Specialist will review the certificates in accordance with the checklist 

and provide feedback to the community. For continued participation in the CRS, at least 

90% of the community’s certificates must be correct, i.e., have no errors on them (a missing 

certificate counts as an error). If less than 90% of the certificates pass, the community must 

correct them to maintain CRS participation. A community is given two chances (the initial 

submittal plus one opportunity to make corrections) to submit the proper certificates to

achieve 90% accuracy.

A community’s fulfillment of its construction certificate management requirement for 

achieving Class 9 is based on the review of certificates on the community’s annual 

recertification due date: it is not part of the cycle verification process. During the year of a 

community’s cycle verification, the required construction certificates will be reviewed by 

the CRS Resource Specialist in the same manner and at the same time as the community’s 

recertification review, with one difference: only the Permit List and required certificates 

need to be submitted to the CRS Resource Specialist for that year’s review. The rest of the 

documentation needed for recertification will be submitted and reviewed according to the 

cycle verification process (see Section 230). Separating the two processes during a 

verification year keeps the community’s reporting period and due date for construction

certificates the same from year to year. 

If a community needs to make corrections to its Permit List and/or construction certificates, 

the reporting dates do not change. The list and certificates will be reviewed again at the 

next recertification due date. If a community cannot achieve the 90% accuracy requirement, 

it will lose its participation in the CRS at the effective date of the next Flood Insurance 

Manual. 
Addendum to the 2017 CRS Coordinator’s Manual A-25 Edition: 2021 

Related Updates and Corrections

 On page 300-4, Section 301 is renumbered so that its title is replaced with this:

302 Impact Adjustments for Buildings 

 On page 300-4, Section 301.a is renumbered so its title is replaced with this:

302.a. Definition of “Building” 

 On page 300-5, Section 301.b is renumbered so its title is replaced with this:

302.b. Pre- and Post-FIRM buildings 

 On page 300-5, Section 302 is renumbered so that its title is replaced with this:

303 Impact Adjustment Ratio 

 On page 300-5, Example 302-1 is renumbered so its title is replaced with this: 

Example 303-1.

 On page 300-6, Table 302-1 is renumbered so that its title is replaced with this: 

 Table 303-1. Impact adjustments for buildings.

 On page 300-6, section 302.a is renumbered so that its heading is replaced with this:

 303.a. Counting Buildings 

 On page 300-7, section 302.b is renumbered so that its heading is replaced with this:

 303.b. bSF (buildings in the SFHA) 
Addendum to the 2017 CRS Coordinator’s Manual A-26 Edition: 2021 

Addendum to

Section 310 of the CRS Coordinator’s Manual, 2017 Edition

Summary

As noted above, much of the background material from Section 311 was moved to the 

new Section 301. What remains has been re-organized slightly.

To better reflect the scope of the community’s responsibility in applying construction 

standards to mitigate flood losses, the element EC is renamed CCMP, for construction 

certificate management procedures. A new Section 312.a is inserted as explanation.

 In the Summary box on page 310-1, Section 312.a is revised to read: 

a. Construction certificate management procedures (CCMP): 38 points for 

a community’s having written procedures that document how the

community collects, reviews, corrects, maintains, and makes available to 

all inquirers the Federal Emergency Management Agency (FEMA) 

Elevation Certificates, FEMA Floodproofing Certificates, V-Zone design 

certificates, engineered openings certifications, and FEMA Residential 

Basement Floodproofing Certificates required for buildings built in the 

Special Flood Hazard Area (SFHA) after the date of application to the 

Community Rating System (CRS). All communities must receive credit for 

this element. 

 In the Summary box on page 310-1, the Credit Criteria are replaced with this 

simplified revision:

Credit Criteria

Each element has a separate section describing its credit criteria.

 In the Summary on page 310-1, the Impact Adjustment section is replaced with this 

revision, which reflects the re-naming of element EC to CCMP:

Impact Adjustment

There is no impact adjustment for CCMP. The credit for ECPO and ECPR is 

adjusted based on the number of post-FIRM and pre-FIRM buildings in the 

community. 
Addendum to the 2017 CRS Coordinator’s Manual A-27 Edition: 2021 

Revision of Activity 310

 Under 310 ELEVATION CERTIFICATE MANAGEMENT on page 310-2, the introductory 

paragraph and all of 311 Background are replaced with the following: 

310 CONSTRUCTION CERTIFICATE MANAGEMENT 

The OBJECTIVE of this activity is to maintain correct floodplain-related construction 

certificates—Federal Emergency Management Agency (FEMA) Elevation Certificates, 

FEMA Floodproofing Certificates, V-Zone design certificates, engineered openings 

certifications, and FEMA Residential Basement Floodproofing Certifications—for new and 

substantially improved buildings in the Special Flood Hazard Area (SFHA) as well as for

development that existed before the community joined the CRS. This activity also addresses 

how a community provides for the management of certificates when development occurs.

311 Background

Because most building data are recorded on FEMA Elevation Certificates, Activity 310 is 

called “Elevation Certificates,” but the discussion and criteria cover all other required 

floodplain-related construction certifications as well, as listed in Section 301.b.

The construction of new buildings, the substantial improvement of existing buildings, and 

the reconstruction of buildings due to substantial damage in the SFHA all require diligent 

oversight by a community. Comprehensive procedures that cover the collection, review, 

processing, maintenance, and public accessibility of all required certificates are essential to 

effective floodplain management. Unclear direction on when to require certain certificates, 

who performs inspections, who conducts reviews, or how certificates are stored for future 

use can result in mis-rated insurance policies as well as possible NFIP non-compliance. 

Casual procedures also result in inconsistent, missing, and lost permit documentation. 

Therefore, a community that participates in the CRS is required to create and update written 

management procedures for the handling of its floodplain-related construction certificates.

A prerequisite for reaching Class 9 in the CRS is maintaining required construction 

certificates from the date of a community’s CRS application forward. This helps ensure 

appropriate development practices once a community joins CRS, but usually development 

already exists in the SFHA when the community joins the CRS. Accurate elevation and 

other data about those buildings, and whether they were built pre-FIRM or post-FIRM, are

important for compliance and insurance purposes. 

This activity provides credit to communities that create written procedures on how required 

floodplain-related construction certificates are obtained, reviewed, corrected, maintained, 

and made available to the public. Credit is also provided under this activity for complete 

and accurate Elevation Certificates on pre-FIRM and post-FIRM buildings.
Addendum to the 2017 CRS Coordinator’s Manual A-28 Edition: 2021 

 Beginning on page 310-2, portions of Section 311.a have been moved to new Section 

301. Section 311.a is replaced with this revised subsection:

311.a. Activity Description 

The maximum credit for Activity 310 is 116 points.

Credit is provided if the community creates written procedures that address the collection, 

review, correction, and maintenance of FEMA Elevation Certificates, FEMA Floodproofing 

Certificates, V-Zone design certificates, engineered openings certifications, and FEMA 

Residential Basement Floodproofing Certificates required for new buildings, substantially 

improved buildings, or buildings reconstructed due to substantial damage in the SFHA (see 

Section 301.b) after the community’s initial date of application for the CRS. The procedures 

must describe how the community will make the construction certificates available to any 

inquirer. The community must review the certificates to ensure a minimum 90% accuracy. 

Credit is also provided if the required construction certificates are obtained and correct for 

pre-FIRM and post-FIRM buildings in the SFHA. For CRS purposes, copies of these 

certificates may have been obtained recently or may have been part of the community’s 

permit archive system. The certificates must be for “finished construction” and kept on 

FEMA forms. Elevation data for pre-FIRM or post-FIRM buildings can be entered on the 

current FEMA forms rather than on the form in effect at the time the building was built. 

 On pages 310-5 through 310-11, subsections 312.b and 312.c are replaced with new 

subsections as follows:

311.b. Activity Impact Adjustment 

There is no impact adjustment for CCMP. The impact adjustment ratios for ECPO and 

ECPO are included in the calculations for those two elements.

311.c. Credit Verification

For CCMP credit, the community must submit a copy of its current written procedures on 

how required construction certificates are obtained, reviewed, maintained, and made 

available to the public. If the community has all the items addressed in Section 312.a, 

Credit Criteria, credit will be given. Failure to have all items will result in no credit.

For ECPO and ECPR credit, the community must send its ISO/CRS Specialist a copy of the 

required construction certifications for all new buildings, substantial improvements, and 

reconstructions due to substantial damage in the SFHA during the appropriate time period 

(pre-FIRM or post-FIRM) since the last cycle verification visit. The information to be 

included is listed in Section 312.a, Documentation for ECPO [and ECPR] Provided by the 

Community. 
Addendum to the 2017 CRS Coordinator’s Manual A-29 Edition: 2021 

The community also must submit the total number of buildings built during the pertinent 

time period (pre-FIRM or post-FIRM), along with the total number of construction 

certificates submitted for credit. 

The Insurance Services Office, Inc., (ISO) will review the certificates in accordance with 

the checklist and current sampling procedures and provide feedback to the community. The 

community’s credit for ECPO and ECPR is based on this first review. For example, if the 

community has 20 certificates but only 12 have no problems listed on the checklist, the 

community’s credit will be

 ECPO = 48 x 12 = 28.80 points 

 20 

The credit for ECPO and ECPR is based on the first review of certificates submitted for the 

verification visit. It will not change after the community makes the needed corrections, but 

it can be rescored at the next visit based on a review of the next batch of certificates.

The certificates for ECPO and ECPR do not need to meet the 90% accuracy threshold. If 

there are problems on any certificates, the score is applied for the correct certificates and 

those that had problems can be corrected for the next cycle verification. There is no 

opportunity to increase the credit for the verification visit. The number of pre- and postFIRM buildings is relatively static, unless there has been a map change or annexation in the 

SFHA since the previous verification. In those instances, the entire element will be reevaluated and likely would be re-scored.

At each annual recertification date, the community again must provide a permit list, 

showing all buildings in the SFHA that are new, substantially improved, or reconstructed 

due to substantial damage during the previous year, along with copies of the required 

construction certificates for those buildings. These are reviewed and feedback given to the 

community. This review determines compliance with the Class 9 prerequisite. This is 

discussed in detail in Section 301. Annual verification of ECPO or ECPR is not required. 

Revised Approach to Elevation and Other Certificates 

 Under 312.a, Maintaining Elevation Certificates on pages 310-12 and 312-13, the 

entire subsection is replaced with this:

312.a. Construction certificate management procedures (CCMP) 

Credit for this element is 38 points.

CCMP credit is provided if the community maintains written procedures for the collection, 

review, correction, maintenance, and public accessibility of the required floodplain-related 

construction certificates (listed in Section 301.b) after the date of its application to the CRS. 
Addendum to the 2017 CRS Coordinator’s Manual A-30 Edition: 2021 

If no buildings have been built or substantially improved in the SFHA since the CRS 

application date, the community can still receive credit for this element. The CRS prefers to 

see no buildings in the floodplain rather than provide credit for having records on those that 

have been built. 

All communities are required to receive credit under this element in order to continue 

participation in the CRS (Class 9 prerequisite).

Credit Criteria for CCMP

(1) The procedures must be in writing, approved by the head of the department(s) that 

oversees the staff and duties included in the procedures, and updated when needed. 

The procedures must include the following:

(a) A description of what types of construction certificates are required by the 

community. The certificates required by FEMA and the CRS are listed in Section 

301.b, but not all certificates are applicable to all communities, so the community 

needs to provide a list of which certifications are required within its jurisdiction.

(b) A description of when the construction certificates are required by the 

community. The written procedures must specify the points during the permitting 

process at which the various certificates are required to be submitted, along with 

the community requirements for obtaining a complete and correct finishedconstruction certificates before a certificate of occupancy is issued. For 

communities that do not issue certificates of occupancy, there must be an 

explanation that finished-construction certificates are required before a permit is 

finalized. 

(c) A description of what department or office collects the required certificates and 

at what point this is done during the permitting process. A brief discussion 

should include how a certificate is processed through the permitting system.

(d) A description of what department or office reviews the required certificates and 

at what point this is done during the permitting process. Details must be included 

on who reviews the certificates (titles are acceptable), what their qualifications 

are (e.g., CFM or NFIP training), and at what point in the permitting process 

reviews are done.

(e) A description of how the certificates are corrected. The written procedures 

must give details on who specifically works with the certifier and how the 

process works. Attention must be given to how corrected certificates are relayed 

back to the professional who originally certified the form(s) so that future errors 

are minimized, and to the current property owner, because the error may affect 

the insurance rating of the building.

(f) A description of how and where the certificates are maintained by the 

community. Details must be included on whether certificates are stored as hard 

copies or digitally (or other), how soon they are filed/stored/archived after they 

are processed, where they are filed/stored/archived, any data backup procedures, 

and whether certificates for new development are stored differently than 

certificates on older buildings.
Addendum to the 2017 CRS Coordinator’s Manual A-31 Edition: 2021 

(g) A description of how the certificates are made available to inquirers. There 

must be an explanation of which department or office handles the request and the 

timeliness (and costs, if any) of fulfilling requests. If a community receives credit 

for having certificates from before it applied to the CRS, it must be able to 

retrieve those certificates, including those from projects whose permit files may 

have been archived or discarded.

(h) If a community requires certificates for development outside of the SFHA, this 

should be addressed appropriately in the written procedures. 

Credit Points for CCMP

CCMP = 38 points for maintaining written procedures that address 

the collection, review, correction, maintenance, and the public 

accessibility of the required floodplain-related construction 

certifications

Impact Adjustment for CCMP

There is no impact adjustment because communities must require, review, and maintain 

copies of required construction certificates on ALL new construction and substantial 

improvement. There is no credit under this activity if the written procedures do not cover 

all required credit criteria.

Documentation for CCMP Provided by the Community

(1) At each verification visit,

(a) The written procedures, including the signature/approval of the appropriate 

department head, describing how the community requires, reviews, corrects, 

maintains, and provides copies of construction certificates to inquirers as 

outlined in the credit criteria section for CCMP.

 Under Credit Criteria for ECPO on page 310-14, the one-sentence criterion is replaced 

by the following new criteria:

Credit Criteria for ECPO

(1) The community must maintain all required construction certificates described in 

Section 301.b for all buildings in the SFHA that have been newly constructed, 

substantially improved, or reconstructed due to substantial damage during the period 

credited. “Buildings” are defined in Section 302.a.

(2) The community must review the certificates to ensure that they are complete and that 

the information is correct, and make copies of the certificates readily available to 

anyone upon request, following the process described in the community’s construction 

certificate management procedures required in Section 312.a. See also Section 301.c, 

Construction Certificate Checklists and Section 301.d, Getting Correct Construction

Certificates.
Addendum to the 2017 CRS Coordinator’s Manual A-32 Edition: 2021 

 Under Credit Criteria for ECPR on page 310-15, the one-sentence criterion is 

replaced with the following new criteria:

Credit Criteria for ECPR

(1) The community must maintain all required construction certificates described in 

Section 301.b for all buildings in the SFHA that have been newly constructed, 

substantially improved, or reconstructed due to substantial damage during the period 

credited. “Buildings” are defined in Section 302.a.

(2) The community must review the certificates to ensure that they are complete and that 

the information is correct, and make copies of the certificates readily available to 

anyone upon request, following the process described in the community’s construction 

certificate management procedures required in Section 312.a. See also Section 301.c, 

Construction Certificate Checklists and Section 301.d, Getting Correct Construction 

Certificates.

 The calculation formula for Activity 310 on page 310-17 is replaced with this: 

313 Credit Calculation

c310 = cCCMP + cECPO + cECPR, where

cCCMP = the verified credit for the element CCMP based on 

whether the written procedures met all criteria, 

cECPO = ECPO x rECPO, and

cECPR = ECPR x rECPR

 In Example 313-1 on page 310-17 the illustration of the scoring process is replaced 

with the following:

Example 313-1.

A community has had Elevation Certificates to submit at each 

recertification due date since its previous cycle. The community is required 

to produce written procedures covering all the required credit criteria. The 

ISO/CRS Specialist has determined the procedures have met all criteria.

 cCCMP = 38 

The community has correct Elevation Certificates for 10 of its 22 postFIRM buildings. As discussed above, rECPO = 0.45. 

cECPO = 48 x 0.45 = 21.60 
Addendum to the 2017 CRS Coordinator’s Manual A-33 Edition: 2021 

The community has Elevation Certificates for 122 of its 250 pre-FIRM 

buildings. As discussed above, rECPR = 0.49.

cECPR = 30 x 0.49 = 14.70

c310 = cEC + cECPO + cECPR 

c310 = 38 + 21.60 + 14.70 = 74.30, which is rounded to 74

Related Updates and Corrections

 Because element EC is changed to CCMP, reference to EC in the first bullet of 

Example 220.c-1 on page 220-3 is also changed:

Example 220.c-1.

The elements and their acronyms in Activity 310 (Elevation Certificates) are 

• CCMP, credit for construction certificate management procedures; 

 On page 220-4, in the paragraph below the bulleted list, reference to EC is 

eliminated. The replacement paragraph reads:

A community need not apply for all of the elements in an activity in order to receive credit 

points for the activity. However, in some cases, one element may be required in order to 

obtain any credit. For example, MI1 is a prerequisite for any Activity 320 credit. These 

requirements are shown in the “Credit Criteria” section of the activity or element.
Addendum to the 2017 CRS Coordinator’s Manual A-34 Edition: 2021 

Addendum to

Activity 370 of the CRS Coordinator’s Manual, 2017 Edition

Summary

The maximum credit points for a flood insurance coverage improvement plan 

(element CP) and for providing technical assistance on flood insurance (element TA) are 

increased. Three new creditable elements are introduced: providing credit for 

distributing flood insurance information (element FIB), for holding insurance-related 

town hall meetings (element FIM), and for a state requirement for continuing education 

for flood insurance agents (element SCE). 

 In the Summary box on page 370-1, the credit points and elements sections are 

revised, and three new elements are added, to read:

Maximum credit: 220 points 

372 Elements

a. Flood insurance coverage assessment (FIA): Up to 15 points for 

assessing the community’s current level of coverage and identifying 

shortcomings. 

b. Coverage improvement plan (CP): Up to 30 points for a plan prepared by 

a committee that has representation from local insurance agents.

c. Coverage improvement plan implementation (CPI): Up to 60 points for 

implementing the projects in the CP plan.

d. Technical assistance (TA): Up to 35 points for providing advice about 

flood insurance.

e. Flood insurance brochures (FIB): Up to 25 points for including flood 

insurance information with building permits or other direct distribution.

f. Flood insurance meeting (FIM): Up to 40 points for a community town 

hall meeting or open house to promote flood insurance.

g. State-required continuing education (SCE): Up to 15 points for a state 

requirement for continuing education on flood insurance for insurance 

agents. 
Addendum to the 2017 CRS Coordinator’s Manual A-35 Edition: 2021 

 Section 371.a, beginning on page 370-3, is replaced with new language through 

which the credit points for a coverage improvement plan—CP and for technical 

assistance—TA are increased, and the three new elements are summarized. The new 

Section 371.a appears below.

371.a. Activity Description

The maximum credit for this activity is 220 points.

As noted under Activity 330 (Outreach Projects), one of the most effective ways to get a 

message across is to have it tailored to local audiences and repeated by different sources. This 

activity credits a similar approach to improve flood insurance coverage in a community.

This activity provides credit for a three-step process that allows communities to assess their 

own needs and receive credit for improving their coverage:

Step 1. Flood insurance coverage assessment (FIA). This element provides credit for 

assessing the community’s current level of coverage and identifying shortcomings. The 

maximum credit for FIA is 15 points.

Step 2. Coverage improvement plan (CP). The plan is prepared by a committee that has 

representation from local insurance agents. The maximum credit for CP is 30 points.

Step 3. Implementation of the coverage improvement plan (CPI), Flood insurance 

brochures (FIB), and Flood insurance meeting (FIM)). The plan’s projects are implemented. The maximum credit for CPI is 60 points, FIM is 25 points, and FIB is 40 points. 

Credit for the three steps or elements is provided incrementally. That is, a community first 

prepares an assessment and circulates it for review and may request credit for that step in 

element FIA (Section 372.a). If the community then decides to proceed with a coverage 

improvement plan, credit is provided for that step in element CP when the plan is submitted 

to the governing body (Section 372.b). Finally, implementing the projects described in the 

coverage improvement plan is credited in element CPI (Section 371.c). 

Credit is also available under this activity for technical assistance (element TA), i.e., providing 

advice about flood insurance similar to the flood protection assistance service credited under

Activity 360 (Flood Protection Assistance). The maximum TA credit is 35 points.

Credit is available for flood insurance projects that are credited in element CP and element 

CPI that involve handing a flood insurance brochure directly to people (element FIB in 

Section 371.d), and for flood insurance open houses or town hall meetings at which one-onone flood insurance advice is provided (element FIM in Section 371.e). Credit for FIB and 

FIM are provided, as appropriate, with CPI.

Credit is also available to a community under element SCE when the state requires that 

insurance agents receive continuing education credit on flood insurance. 
Addendum to the 2017 CRS Coordinator’s Manual A-36 Edition: 2021 

Increased Credit for Elements CP and TA

 Under Coverage Improvement Plan on page 370-6, the credit points for CP are 

increased by replacing the first paragraph with this sentence:

372.b. Coverage improvement plan (CP)

The maximum credit for this element is 30 points.

 Under Credit Criteria for CP when it continues onto page 370-9, a new alternative is 

introduced by inserting a new subsection (7):

(7) Additional credit is available when the committee in credit criterion (2) includes two or 

more insurance agents (and comprises at least six people) and at least one agent is an 

Associate in National Flood Insurance (ANFITM). The insurance agents must participate 

in all meetings.

 Under Credit Points for CP on page 370-9, the points are revised with this 

replacement:

Credit Points for CP

CP = 15 points, for the development of the coverage improvement 

plan, 

plus

15, if two local insurance agents participate on the 

committee and at least one is an Associate in National Flood 

Insurance (ANFITM) 

More information on the ANFI® certificate can be found at http://www.aicpcu.org/anfi. 

 Under Technical Assistance on page 370-12, the credit is increased by replacing the 

first paragraph with this sentence:

372.d. Technical assistance (TA)

The maximum credit for this element is 35 points.
Addendum to the 2017 CRS Coordinator’s Manual A-37 Edition: 2021 

 Under 372.d Technical assistance (TA) on page 370-12, a typographical error is 

corrected by replacing the second paragraph with this: 

This credit is separate from FIA, CP, and CPI. The community does not need to prepare a 

flood insurance assessment or coverage improvement plan for this credit. However, the 

coverage improvement plan should discuss providing this technical assistance as a way to 

encourage people to purchase, maintain, or improve their coverage. If the service is credited 

under TA, it cannot also be credited as a CPI or OP project. 

 Under Credit Points for TA on page 370-13, the formula is revised to reflect the 

increased credit. The new formula is this:

TA = the total of the following:

20, for providing the technical assistance service,

plus

15, if the service is provided by an Associate in National 

Flood Insurance (ANFITM)

New Credit for Flood Insurance Brochures and Meetings

and State-required Continuing Education

 On page 370-13, three new credit elements are added by inserting the following: 

372.e. Flood insurance brochures (FIB) 

The maximum credit for this element is 25 points.

FIB credit is provided when the community distributes flood insurance brochures to 

residents and property owners. 

This credit is additional credit with CP, and CPI. If the brochure is credited under FIB, it

cannot also be credited as an OP project.

Credit Criteria for FIB

(1) The community must be receiving CP and CPI credit. Element FIB provides additional 

credit for implementing a project described in the CP.
Addendum to the 2017 CRS Coordinator’s Manual A-38 Edition: 2021 

(2) If the distribution of brochures is done by including them with issued permits, then the 

brochures must be included with all building permits issued throughout the community.

(3) If the distribution takes the form of a mailing to all residents, then the brochure must be

specifically related to flood insurance and must be mailed at least annually to all 

residents of the SFHA, at a minimum. Messages about flood insurance that are included 

in other documents do not qualify for this credit. 

(4) Records of the brochure distribution must be kept and provided for credit 

documentation.

Credit Points for FIB

FIB = the total of the following:

15, for providing a flood insurance brochure along with every 

building permit issued throughout the community, 

and

10, for annually mailing a flood insurance brochure at least to all 

residents of the SFHA. 

Documentation for FIB Provided by the Community

(1) At each verification visit,

(a) A copy of the brochure.

(b) A description of when and how the brochure is provided.

(2) With the annual recertification,

(a) Same as above.

372.f. Flood insurance meeting (FIM) 

The maximum credit for this element is 40 points.

Credit Criteria for FIM

(1) The community must be receiving CP and CPI credit. FIM is additional credit for plan 

implementation of a project described in the credited coverage plan. 

(2) The townhall meeting or open house must be for the specific purpose of the 

promotion, education, and assistance with flood insurance. Other public information 

may be provided at the event. 

(3) The townhall meeting or open house must be promoted to all community residents and 

property owners
Addendum to the 2017 CRS Coordinator’s Manual A-39 Edition: 2021 

(4) The townhall meeting or open house must be held at least once a year. 

(5) Additional credit is provided if a representative of the State Insurance Commissioner’s 

office participates each year in the townhall meeting or open house. Participation 

means the Insurance Commissioner attends the event or sends a representative, and he 

or she engages with attendees by speaking or being accessible to answer insurance 

questions.

Credit Points for FIM

FIM = the total of the following:

20, for an annual townhall meeting or open house about flood 

insurance,

plus

20, if the State Insurance Commissioner’s office participated

Documentation for FIM Provided by the Community

(1) At each verification visit,

(a) A copy of publicity of the meeting or open house and a copy of a sign-in sheet

from the townhall meeting or open house.

(b) Documentation of the involvement of the State Insurance Commissioner.

(2) With the annual recertification,

(a) [Same as above.]

372.g. State-required continuing education (SCE) 

The maximum credit for this element is 15 points.

SCE credit is provided to all communities within a state where insurance agents are 

required by the state to obtain continuing education credits for flood insurance.

Credit Criteria for SCE

(1) The community must be receiving CP credit. 
Addendum to the 2017 CRS Coordinator’s Manual A-40 Edition: 2021 

Credit Points for SCE

SCE = EITHER

7 points, if the state mandates an initial three continuing education 

credits in flood insurance and a renewal course at least every

four years, 

OR

15 points, if the state mandates continuing education credits in flood 

insurance at every license renewal for insurance agents

Documentation for SCE Provided by the Community

(1) At each verification visit, 

(a) A copy of or link to the state statue or state order that requires continuing 

education. 

 Under 374 Credit Calculation on page 370-13, the formula is revised to include the 

new elements: 

c370 = FIA + CP + CPI + TA + FIB + FIM + SCE
Addendum to the 2017 CRS Coordinator’s Manual A-41 Edition: 2021 

Addendum to

Section 403 of the CRS Coordinator’s Manual, 2017 Edition

Correction

 Table 403-1 under Section 403 Impact Adjustment Map, on page 400-7 shows that 

an impact adjustment is applied to the scoring for problem site maintenance, 

element PSM, under Activity 540 (Drainage System Maintenance). The element PSM 

is removed from the table. There is no impact adjustment for PSM.
Addendum to the 2017 CRS Coordinator’s Manual A-42 Edition: 2021 

Addendum to

Section 404 of the CRS Coordinator’s Manual, 2017 Edition

Summary

This section is revised slightly to explain that the CRS uses the National Climate 

Assessment’s sea level rise projections and data, and to provide a formula for applying a 

multiplier to certain regulatory elements when a community takes sea level rise into 

account.

Updates to Sea Level Rise Projections

 Section 404 Sea Level Rise Projections and the CRS, on pages 400-14 and 400-15, is 

replaced with this updated material:

404 Sea Level Rise Projections and the CRS

The CRS incorporates the consideration of sea level rise into a number of elements, 

including element HHS credit for higher study standards under Activity 410 (Flood Hazard 

Mapping); CEOS credit for coastal erosion open space under Activity 420 (Open Space 

Preservation); CAZ credit for Coastal A Zones under Activity 430 (Higher Regulatory 

Standards); and WMP credit for a watershed master plan under Activity 450 (Stormwater 

Management). Including sea level rise in WMP is required for coastal communities to meet 

the Class 4 prerequisite, and HSS and CAZ credit with future-conditions hydrology is a 

Class 1 prerequisite. CRS prerequisites are described in Section 211.

Recognizing that (1) there is uncertainty inherent in estimating future sea levels, and (2) the 

accuracy of the models continues to improve, the CRS has adopted a “best available data” 

baseline for crediting community efforts to address sea level rise.

In alignment with 13 federal agencies, the CRS defers to the Congressionally mandated 

National Climate Assessments produced by the U.S. Global Change Research Program to 

determine a baseline. These reports are accessible at https://www.globalchange.gov/whatwe-do/assessment.

Because sea levels are changing at different rates in different parts of the country, global 

projections must be adjusted to take local conditions into consideration. To do this, the CRS 

uses and recommends the U.S. Army Corps of Engineers’ “Sea-Level Change Curve 

Calculator,” an online-tool available at https://coast.noaa.gov/digitalcoast/tools/curve.html. 

The CRS anticipates that findings from future National Climate Assessments will be 
Addendum to the 2017 CRS Coordinator’s Manual A-43 Edition: 2021 

incorporated into the Sea-Level Change Curve Calculator. If not, then the CRS will provide 

further guidance to communities, as needed.

For information, outreach, and planning elements (including those under Activities 410, 

450, and 510) and meeting CRS Class prerequisites, the community must project out at least 

to the year 2100 using the intermediate-high projection from the latest-available National 

Climate Assessment projection at the time of its planning process.

For regulatory elements (Activities 420 and 430), credit is awarded on a graduated scale 

based on comparing the projected sea levels the community uses for these elements to the 

most recent National Climate Assessment intermediate-high projection for 2100 at the time 

of the verification visit. This formula updates how the “CFSL” variable in 420 CEOS and 

430 CAZ is calculated.

CFSL = 1.5 x Community projection , where

 Baseline projection

Community projection = the projected future sea level used 

by the community for the credited element in units of height,

and

Baseline projection = the intermediate-high projection of 

future sea level from the latest National Climate Assessment

at the time of the community’s verification visit, localized for 

2100 in units of height.

The maximum value for CFSL = 1.5
Addendum to the 2017 CRS Coordinator’s Manual A-44 Edition: 2021 

Addendum to

Activity 420 of the CRS Coordinator’s Manual, 2017 Edition

Corrections

 In Section 421. Activity Description on page 420-2, a typographical error in the 

number of maximum points is corrected. The new line reads:

421.a. Activity Description 

The maximum credit for Activity 420 is 2,870 points. 

 In Example 422.b-1 on page 420-13, a typographical error in the calculation is 

corrected. The new line reads:

rDR = aDR = 55.30 = 0.11

aSFHA 504.40
Addendum to the 2017 CRS Coordinator’s Manual A-45 Edition: 2021 

Addendum to

Activity 430 of the CRS Coordinator’s Manual, 2017 Edition

Summary

To simplify scoring and documentation, state-mandated standards are being eliminated 

as a separate creditable element of the CRS. Communities will continue to receive credit 

for all state standards (building codes, freeboard, stormwater, etc.) under other 

elements and activities in the CRS. As a result of this change, references to element SMS

at other locations in the Coordinator’s Manual are eliminated.

Discontinuation of State-mandated Standards (element SMS)

 In the Summary box on page 430-1, under Credit Elements, item (p) State-mandated 

regulatory standards, is deleted. Item (q) is re-labeled. The last element in the list is 

therefore:

p. Regulations administration (RA): Up to 67 points for having trained staff and 

administrative procedures that meet specified standards.

 Sub-section 430.p, State-mandated standards (SMS), beginning on 

page 430-53, is deleted. 

Related Updates and Corrections

 Because element SMS is discontinued, references to SMS on the following pages are

deleted:

430-4 (Impact Adjustment), 430-60 (Credit Calculation), and 430-61 (Example)

 Sub-section 430.q, Regulations administration, on page 430-55, is re-labeled to 

read:

430.p. Regulations administration
Addendum to the 2017 CRS Coordinator’s Manual A-46 Edition: 2021 

Addendum to

Activity 450 of the CRS Coordinator’s Manual, 2017 Edition

Summary

Some language for element SMR—stormwater management regulations—is revised to 

focus the credit on the area over which the community has jurisdiction, instead of on 

the entire watershed, which usually extends outside the community.

Focus on Community’s Jurisdiction for Stormwater Management

 In the Summary box on page 450-1, the Impact Adjustment description is revised to 

narrow the focus to the community’s jurisdiction:

Impact Adjustment 

The credit points for SMR and WMP are adjusted by ratios reflecting the proportion 

of the community affected by the regulations or the plan. There is no impact 

adjustment for elements ESC or WQ.

 Under 452.a Stormwater Management Regulations on page 450-4, the first 

sentence of the second paragraph is revised to narrow the focus to the community’s 

jurisdiction. The new paragraph reads as follows:

SMR credits the regulations used by the community to manage runoff from future 

development onsite. SMR credit is provided if new development is required to prevent or 

reduce the increase in runoff that results from urbanization. SMR credit is only provided for 

regulation of runoff from a 10-year storm or larger. Additional credit is available if the 

community addresses larger storms and controls the total volume of runoff from new 

development.

 Under Credit Criteria for SMR on page 450-5, criterion (1) is replaced with the 

following to focus on the community’s jurisdiction: 

(1) A portion of the community must be subject to a regulation that requires the peak 

runoff from new development to be no greater than the runoff from the site in its predevelopment condition. 
Addendum to the 2017 CRS Coordinator’s Manual A-47 Edition: 2021 

 Under Credit Points for DS, where it continues on page 450-8, a sentence is added to 

the first paragraph to clarify the calculation. The replacement paragraph is as 

follows:

The regulations must require pre- and post-development hydrology calculations and postdevelopment runoff must be limited to pre-development levels at the site boundary (credit 

criterion (5)). The standard used may be peak flow, volume, or a combination of the two. If 

the volume of runoff is controlled by retaining the runoff on site, infiltrating the runoff, or 

ensuring that the volume of runoff during all storms greater than half of the 2-year event 

remains constant, the credit is increased by 50%. If the modified rational method is used to 

design detention facilities for areas larger than one acre, the total credit for DS is reduced 

by 50%.

 The subsection Impact Adjustment for SMR, on page 450-11, is revised to reflect a 

focus on the community’s jurisdiction. The entire subsection is replaced with the 

following:

Impact Adjustment for SMR

The impact adjustment for SMR is based on the area of the community that is regulated by 

the SMR regulations (aSMR) and the total area of the community (aW). See Sections 402 

and 403 on calculating an impact adjustment. 

In order to determine aSMR when the regulations are not uniform throughout the 

community, the community must prepare an impact adjustment map (see Section 403.d) and 

calculate the area of the community and the area subject to each of the regulations. The 

base map for the impact adjustment map should be a map that shows the entire community 

and where each set of regulations is in effect within the community. The total area of the 

community is represented by aW. 

Many very large communities regulate stormwater only in portions of their jurisdictions.

With appropriate documentation, parts of the community may be excluded from aW if,

because of their ownership, they are unlikely to be developed. Such areas could be national 

forests, state parks, Tribal lands, or privately owned land dedicated to open space use.

Communities are encouraged to cooperate with adjacent communities to manage 

stormwater. If a community only has regulatory jurisdiction over a portion of its 

watersheds, it cannot ensure that properties will be safe from increased runoff in the future, 

because of upstream development. However, if upstream communities also manage future 

development, either independently or through county-wide or watershed regulations, all 

communities can benefit. 

If the community does not regulate development throughout the entire community and 

wants an impact adjustment ratio greater than 0.15, it must develop an impact adjustment 

map to determine the areas required to calculate rSMR for each area with creditable 

regulations.
Addendum to the 2017 CRS Coordinator’s Manual A-48 Edition: 2021 

rSMR = aSMR, where

 aW

aSMR = the area subject to stormwater management regulation, 

and

aW = the area of the community

If the total calculated impact adjustment is less than 0.15, or the community does not 

prepare an impact adjustment map, then rSMR = 0.15.

Example 452.a-6. 

A community regulates all watersheds within its corporate limits. 

Therefore, 1.0 is used for rSMR.

Related Updates and Corrections

 Under Documentation for SMR Provided by the Community on page 450-13, item 

(d) is eliminated and item (e) is re-labeled and revised to reflect the focus on the 

community’s jurisdiction. The last two items of documentation now read:

(c) Drainage reports that demonstrate enforcement of the regulations. The ISO/CRS 

Specialist determines how many records are needed for a representative sample.

(d) If the community has varying regulatory standards within its jurisdiction, an impact 

adjustment map showing community boundaries and the calculated areas to which the

different stormwater management regulations are applied.

 Under 452.b Watershed Master Plan on page 450-14, the second and third 

paragraphs are revised to focus on the community’s jurisdiction:

WMP credit is provided if the community implements measures to reduce stormwater flooding 

through an adopted watershed master plan. Credit is also provided for watershed master plans that 

• Evaluate future conditions and long-duration storms, 

• Evaluate the impact of sea level rise and climate change,

• Identify wetlands and natural areas, 

• Address the protection of natural channels, and 

• Provide a dedicated funding source for implementing the plan. 
Addendum to the 2017 CRS Coordinator’s Manual A-49 Edition: 2021 

The objective of watershed master planning is to provide the community with a tool it can 

use to make decisions that will reduce the increased flooding from future conditions that 

include new development, redevelopment, and the impact of climate change and sea level 

rise, throughout a watershed or community. Although there is no doubt that stormwater 

management regulations reduce the future flood threat from a developing area, a watershed 

master plan goes much further in locating and dealing with existing problems and 

identifying potential future problems. An understanding of the watershed’s behavior is 

necessary to ensure that established or enhanced stormwater management regulations 

requiring onsite control will prevent flood damage due to future development.

 Under Credit Criteria for WMP on page 450-15, paragraph (2) is revised to eliminate 

SMR credit as a prerequisite to receiving WMP credit. The replacement text reads:

(2) The community must have adopted a plan to address all flooding issues identified for 

at least the 10-year storm in addition to the 25-year event. Management of a 2-year 

storm is also recommended.

 Under Impact Adjustment for WMP on page 450-17, the subsection is replaced by 

the following, eliminating the requirement for a correlation between the impact 

adjustment map for SMR and that for WMP:

Impact Adjustment for WMP

The impact adjustment map for WMP is prepared, and the affected areas are calculated in 

the same manner as for SMR in Section 452.a. 

rWMP = aWMP , where

 aW

aWMP = the area covered by a watershed master plan

If the total calculated impact adjustment is less than 0.15 or the community does not 

prepare an impact adjustment map, then rWMP = 0.15. 

 Under Documentation for WMP Provided by the Community on page 450-18, item 

(vii) is eliminated and item (vi) is replaced with the following:

(vi) The impact adjustment map.
Addendum to the 2017 CRS Coordinator’s Manual A-50 Edition: 2021 

Addendum to

Section 501 of the CRS Coordinator’s Manual, 2017 Edition

Summary

In Section 501 a few changes are made to update statistics and to reflect alterations to 

the procedures by which communities obtain repetitive loss data.

Updates and Clarifications

 Under 501.a Repetitive Losses on page 500-3, both paragraphs are updated and 

clarified by substituting these two paragraphs:

Repetitive loss properties are those properties for which two or more claims of more than 

$1,000 have been paid by the National Flood Insurance Program (NFIP) within any 10-year 

period since 1978 (e.g., two claims during the periods 1978–1987, 1979–1988, etc.). Other 

definitions of “repetitive,” such as those found in flood damage prevention ordinances, may 

not be used to determine the number of repetitive loss properties in a participating CRS 

community.

Over $12 billion have been paid to repetitive loss properties, about one-fourth of all NFIP 

payments since 1978. Although the NFIP has resulted in over 50 years of successful 

floodplain management, and many of these structures are no longer insured, repetitive loss 

properties are still a drain on the NFIP. 

 Under 501.b The Repetitive Loss List on page 500-3, the third paragraph is replaced 

with this one, which updates the source from which data are obtained:

Each year, communities can obtain updated data by contacting the appropriate FEMA 

Regional Office. This data reflects the community’s previously submitted changes, new 

properties that have been added as a result of recent floods, and changes resulting from 

other communities’ updates. Except during cycle verification and as specified in Section 

502.b, a community is not required under the CRS to respond to each year’s new list. However, 

the list can be a valuable planning tool and source of information about the location and extent 

of flooding within the community. Communities are encouraged to submit any known updates 

every year. 
Addendum to the 2017 CRS Coordinator’s Manual A-51 Edition: 2021 

Addendum to

Section 510 of the CRS Coordinator’s Manual, 2017 Edition

Summary

The total credit available under Section 510 is increased, and new opportunities are 

provided for earning credit. The options for obtaining credit for a plan that protects 

natural floodplain functions (element NFP) are expanded to make an assessment of

threatened and endangered species creditable. New credit is made available in the form 

of a new element, SDP (for substantial damage management plan), for communities 

that devise written procedures for addressing issues related to the risk of substantial 

damage to buildings in their jurisdictions.

Credit Points and Opportunities Increase

 In the Summary box on page 510-1, the credit points are increased to read:

Maximum credit: 762 points

 In the Summary box on page 510-1, paragraph c. is revised to embrace a floodplain 

species plan and a new paragraph d. is added to incorporate the new element SDP.

The replacement paragraphs are as follows:

c. Natural floodplain functions plan (NFP): 100 points for adopting plans 

that protect one or more natural functions within the community’s 

Special Flood Hazard Area. Within NFP is credit for a floodplain species 

assessment and for a floodplain species plan.

d. Substantial damage management plan (SDP): Up to 140 points for a 

community plan to prepare for substantial damage estimates and 

determinations after a flood. 

 In Section 512.a. Floodplain management planning on page 510-4, the credit points 

are increased to read:

512.a. Floodplain management planning (FMP) 

The maximum credit for this element is 762 points.
Addendum to the 2017 CRS Coordinator’s Manual A-52 Edition: 2021 

Species Assessments Qualify for Natural Functions Plan

The options for earning credit for a natural functions plan are being expanded to 

specifically provide that a species assessment can qualify as protecting natural 

floodplain functions. This is done by adding two new sub-elements, FSA and FSP (FSA 

for floodplain species assessment and FSP for floodplain species plan). 

 Under Section 512.c, Natural Floodplain Functions Plan on page 510-35, a fifth 

bullet is added and the note that follows it is updated:

● A floodplain species assessment that identifies the threatened and endangered species 

that have range or critical habitat within the community and a floodplain species plan 

that recommends actions to support conservation or recovery of those species. 

NOTE: Element NFOS2, (section 2 of the natural floodplain functions open space credit 

under Activity 420 (Open Space Preservation)), provides bonus credit for open space 

parcels that are designated in a plan to protect natural functions. A plan that receives NFP 

or FSP credit qualifies parcels for this extra open space credit.

 Under Credit Criteria for NFP, where it continues onto page 510-36, descriptions of 

the species assessment criteria are inserted. The three subsections that follow,

Credit Points for NFP as well as Impact Adjustment for NFP and Documentation for

NFP Provided by the Community are also updated to include the new sub-elements. 

The substitute language is as follows:

(4) For FSA: This sub-element credits a floodplain species assessment that identifies all

threatened and endangered species that have been listed or proposed for listing by the 

U.S. Fish & Wildlife Service or by the National Marine Fisheries Service and that have

range or critical habitat anywhere within the community, relates their locations to the 

floodplain, and reviews current and feasible conservation and recovery actions that 

could receive CRS credit. The draft document must be circulated to federal, state, and 

private organizations that have expertise in protecting threatened and endangered 

species. A floodplain species assessment must meet credit criteria (1)(a), (c), and (e).

(5) For FSP: This sub-element credits taking another step after a floodplain species assessment: a plan that revises the floodplain species assessment and adds action items based 

on the comments and input from the reviewers to make a plan of action. Credit for FSA 

is a prerequisite for FSP credit.

A plan for FSP credit must meet all of credit criterion (1) with the following exception: 

a plan for FSP credit (criterion (1)(d)) is not required to include an inventory of all

threatened and endangered species but may focus instead on selected species, based on 

the comments and recommendations of the reviewers of the FSA-credited assessment.
Addendum to the 2017 CRS Coordinator’s Manual A-53 Edition: 2021 

The community must also prepare and submit an annual evaluation report that meets the 

credit criteria of a floodplain management plan in Section 512.a, Step 10.

Additional guidance for preparing assessments and plans for FSA and FSP credit is listed in 

Section 514.e. 

Credit Points for NFP

NFP = the total of the following, up to the maximum of 100 points:

NFP1 = 100 points, for a plan, or combination of plans, that 

meets credit criteria (1) and (2) and covers the entire SFHA 

within a community

NFP2 = 15 x the number of plans that meet credit criterion (1), 

up to four plans (60 points maximum)

FSA = 15 points for preparing and circulating a floodplain 

species assessment 

FSP = 85 points for preparing and adopting a floodplain species 

plan

Impact Adjustment for NFP

There is no impact adjustment for this element. The NFP1 plan must cover the entire 

community or all of the community’s SFHAs. Each NFP2 plan receives 15 points regardless 

of the extent of the area covered. 

The assessment for FSA credit must start with an inventory of all threatened and endangered 

species that have range or critical habitat anywhere in the community. For the action plan that 

qualifies for FSP credit, however, that list may be trimmed down to focus on selected species 

or areas. Thus, no impact adjustment is needed for either of these sub-elements.

Documentation for NFP Provided by the Community

(1) At each verification visit,

(a) A copy of each plan, assessment, or update that the community wants credited.

(b) A copy of the resolution or other formal adoption action for each plan credited under

NFP or FSP.

(2) With the annual recertification,

(a) A copy of the FSP annual evaluation report (Section 512.c, credit criterion (5)). The 

recertification submittal must also document how the evaluation report and update 

were made available to the media and the public, if this information is not included 

in the evaluation report.
Addendum to the 2017 CRS Coordinator’s Manual A-54 Edition: 2021 

New Credit for a Substantial Damage Management Plan

 The new creditable element for a plan for managing substantial damage is inserted 

at the end of Section 512.c on page 510-36. The insert reads:

512.d. Substantial Damage Management Plan (SDP)

The maximum credit for this element is 140 points.

A management plan for substantial damage within the community is a detailed community 

plan, developed before a flood or other hazardous event, that describes the community’s 

process for evaluating damage to buildings and addressing those that have been

substantially damaged, as required by the NFIP. A management plan for substantial damage 

to properties outlines community responsibilities, identifies available data about buildings 

in the SFHA, describes the community’s approach to damage estimation, and lists the steps 

the community will take if buildings are determined to be substantially damaged. CRS 

credit for a such a plan is provided in element SDP. 

NOTE: The CRS encourages communities to frame their management of substantial damage 

issues within the context of all potential sources of damage to structures (tornado, 

earthquake, hurricane, wildfire, etc.). Further, the definition of “substantial damage” used

by the CRS specifies” damage of any origin” (see definitions box). Some of the language in 

this section is flood-specific, but the discussion is intended to apply to any hazardous event 

that could result in losses and/or damage.

As with a floodplain management plan (element FPM), CRS credit is dependent upon the 

community’s following an appropriate process. Both the steps for developing a substantial 

damage management plan and the content of the plan are important for CRS credit. 

A committee is not required to develop a management plan for substantial damage; 

however, if it does so, the plan should be developed with participation of the community 

CRS Coordinator, the community floodplain administrator, and the building department.

A community may receive CRS credit for element FMP, a repetitive loss area analysis 

(element RLAA), and element SDP. A community need not have any repetitive loss 

properties on FEMA’s list to receive SDP credit.

Addressing substantial damage after a flood or other hazardous event that can damage 

buildings is a requirement of a community’s participation in the NFIP. This activity credits 

plans and actions that a community takes before a flood or other hazard-caused event to 

educate officials and departments, to obtain and utilize as much building data as is available 

for making estimates, and to ensure NFIP compliance. Although the NFIP does require that 

a community address substantial damage caused by any hazard, the substantial damage 

management plan and process for the CRS focuses on floods. 

Three levels of SDP credit are available. The basic credit is 40 points for the development 

of a substantial damage management plan. An additional 50 points are available if FEMA’s 
Addendum to the 2017 CRS Coordinator’s Manual A-55 Edition: 2021 

Substantial Damage Estimator is pre-populated for all properties with the potential to be 

substantially damaged. Another 50 points are provided for communities that consider preflood mitigation alternatives.

Additional guidance for the development of a substantial 

damage management plan is available from the ISO/CRS 

Specialist.

Credit Criteria for SDP

(1) The substantial damage management plan must be 

developed using a definition of substantial damage 

that meets or exceeds the NFIP definition of 

substantial damage (see box at right).

(2) If a community is receiving credit for cumulative 

substantial improvement (element CSI) under

Activity 430 (Higher Regulatory Standards), then the 

substantial damage management plan must reference 

the community’s cumulative substantial damage 

definition credited under CSI and describe the 

community’s process for tracking cumulative 

substantial improvements. If a community is 

receiving credit for having a lower threshold for 

substantial improvement (element LSI), then the 

definition of lower substantial improvement must be 

referenced.

(3) The plan must be the outcome of the following six-step planning process. All steps are 

required, but 2–5 do not have to be done in the order listed. 

Step 1. Assess the community’s vulnerability to substantial damage. This step requires 

the review of all buildings in the SFHA to determine those that are likely to be

substantially damaged. The plan document for this step must include

(a) The definitions of substantial damage and substantial improvement and the 

delineation of a lower damage threshold, as adopted in the community’s 

floodplain management regulations, community-adopted building code, and/or 

state building code. This must include any provisions for cumulative substantial 

damage, substantial improvement, or a lower threshold, if adopted.

(b) A description of substantial damage and substantial improvement 

determinations previously made by the community.

(c) A list and map of SFHA properties with buildings that have the potential to be 

substantially damaged. This could be all the buildings in the SFHA or a subset 

of SFHA buildings. At a minimum, the list should include

o Properties with buildings that are (or are suspected to be) below the 

base flood elevation.

Some Definitions

Substantial damage—As defined in 

44 CFR 59.1 of the NFIP regulations, 

substantial damage is

Damage of any origin sustained by a 

building whereby the cost of restoring 

the building to its before-damage 

condition would equal or exceed 50% of 

the market value of the building before 

the damage occurred.

Substantial improvement is

Any reconstruction, rehabilitation, 

addition, or other improvement to a 

building, the cost of which equals or 

exceeds 50% of the market value of the 

building before the start of construction 

of the improvement.

NOTE: Some ordinances may include 

the repair of flood damage as an 

“improvement” (reconstruction) to the 

building.
Addendum to the 2017 CRS Coordinator’s Manual A-56 Edition: 2021 

o Properties within a repetitive loss area (identified per Section 502.c).

o Properties for which substantial damage estimates have previously 

been provided to the community after a federally declared disaster.

o Any buildings that could meet the 

cumulative substantial improvement

definition, if applicable.

(d) A description of other building or flood factors 

that the community considered during the 

assessment. This could be an adopted procedure 

for tracking cumulative damage and/or 

improvements, or a community-determined flood 

zone not depicted on the FIRM.

(e) A general description of buildings on the 

potential substantial damage list, such as the 

proportion of residential and non-residential. 

Other information should be included, such as

type of structure (single family, manufactured 

home, multi-family, etc.).

The list of properties that could be substantially damaged can be included in a 

document that is separate from the management plan (e.g., a spreadsheet or 

database developed for Step 4).

Step 2. Identify the community’s team for the management of substantial damage 

to properties. A committee is not required for the development of the management 

plan, but a team would be helpful for all the steps.

Although the community floodplain administrator is responsible for ensuring that 

flood damage estimates are obtained after a flood and that substantial damage 

determinations are made when the definition of substantial damage is met, other 

personnel or departments may need to be involved with post-event efforts. In addition 

to the community floodplain administrator, the community should build a team that

(a) Includes the department or office responsible for issuing permits for postevent repairs, and the department or office that tracks CSI, if applicable;

(b) Includes sufficient additional personnel for the substantial damage work 

effort after a major flood or other event. Note that the post-event work effort 

may be reduced depending on the pre-event work (see Step 4); and

(c) Is able to consider other personnel resources, such as the State NFIP 

Coordinator and/or FEMA post-disaster resources.

Step 3. Identify the post-event efforts related to substantial damage. For this 

step, the community should contact the State NFIP Coordinator to obtain any 

Steps to Develop a Substantial 

Damage Management Plan

 1. Assess vulnerability

 2. Assemble a team

 3. Identify post-event actions

 4. Build a database

 5. Identify pre-event actions

 6. Plan implementation & updates

Steps 2 through 5 may be done in 

any order.

An annual evaluation report is 

required.
Addendum to the 2017 CRS Coordinator’s Manual A-57 Edition: 2021 

substantial damage guides or templates that have been developed by the state for 

communities. The community plan must include

(a) Post-event coordination and communication efforts. For example,

o Meetings of the substantial damage management team and training for 

all team members,

o Assigned areas of responsibility for team members (for any or all 

steps),

o Determinations of whether interim permit procedures are needed,

o Communication with elected official, and

o Communication with property owners.

o (b) Damage estimate and substantial damage determination procedures, 

such as

o The conduct of damage inspections of floodplain buildings,

o Making damage estimates for each damaged floodplain building,

o Establishing a market value for each damaged floodplain building,

o Making substantial damage determinations,

o Making substantial improvement determinations,

o Establishing an appeal process for substantial damage/substantial 

improvement determinations, and

o Issuing damage determination letters.

(c) Post-substantial damage determination procedures for compliance, such as

o Enforcing permitting for repairs and mitigation compliance; and

o Providing periodic updates to the State NFIP Coordinator and the 

FEMA Regional Office (or disaster office, if applicable).

Step 4. Build a property database for substantial damage estimates. In Step 1, a 

list of properties that could be substantially damaged was prepared. This step requires 

developing a database for that list that includes the building, building value, and flood 

information.

(a) A basic substantial damage property database is required for SDP credit. Data 

regarding the building such as the property identification number, building 

type (residential/non-residential), foundation type, and the number of stories 

should be included. The fair market value of the building can be obtained 

from assessor’s data. If available, lowest floor and/or first floor elevation 

should be added. 

Communities with CSI credit may reference other databases or documentation 

for tracking cumulative substantial improvements, but all buildings identified 

in Step 1 must be included in a database.
Addendum to the 2017 CRS Coordinator’s Manual A-58 Edition: 2021 

Communities may not include in the substantial damage database any NFIP 

repetitive loss or claims data that are protected by the federal Privacy Act. 

The NFIP information provided to the community (through an Information 

Sharing and Access Agreement, known as an ISAA) is protected by the 

Privacy Act. The database can note which properties are included in a 

“repetitive loss area” (see Section 503). 

Unknown data and desired data should be discussed in the plan. It is 

understood that the database may be expanded or otherwise improved for the 

annual evaluation report or at the time of a required update. Other building or 

property information, such as market value information, should be included as 

available.

(b) [Optional and for SDP2 credit] Pre-populate the FEMA Substantial Damage 

Estimator database. For guidance on using and pre-populating the Substantial 

Damage Estimator, see Section 514, For More Information, on page 510-37.

Step 5. Identify actions the community can take to address potential substantial 

damage. 

(a) The substantial damage management plan must include at least one action the 

community will take to educate the community about substantial 

damage/substantial improvement and the requirements of the NFIP or the 

CRS. Some examples include

o Annual substantial damage training for the substantial damage 

management team members;

o Substantial damage and substantial improvement public information 

(newsletters, social media, information at kiosks);

o Handouts for property owners; and

o Communication with elected officials about community 

responsibilities regarding substantial damage, and if applicable about 

CSI. (This may be sharing the annual evaluation report with the 

elected officials.)

(b) [Optional and for SDP3 credit] Consider mitigation alternatives for areas of 

the community in which buildings have the potential to be substantially

damaged. The best options for properties with a high risk of flooding are 

mitigation actions (buyout, elevation, floodproofing) taken before the next 

flood. The second-best approach is taking mitigation steps after the next 

flood. 

SDP3 credit is provided when each appropriate mitigation alternative is

identified for each neighborhood, area, or other segment of the list of 

properties identified in Step 1. This is beyond the level of detail included in 

multi-hazard mitigation plans. The plan must review alternate approaches and 

determine whether any property protection measures are feasible. The review 
Addendum to the 2017 CRS Coordinator’s Manual A-59 Edition: 2021 

must examine appropriate measures for the types of buildings affected, 

including

o Relocation,

o Acquisition,

o Building elevation, and

o Retrofitting.

A review that looks only at drainage or structural flood control project 

alternatives is not sufficient. For each neighborhood, area, or subset, the 

review must also consider potential local, state, and federal funding sources. 

Step 6. Determine implementation steps and procedures for updating the plan.

The plan must

(a) Provide for an annual evaluation report. The plan document must describe 

who will prepare the annual evaluation and when (see credit criterion 4). 

(b) Be shared with the elected officials, along with the evaluation reports. The 

implementation steps must describe the options for communicating the 

substantial damage management plan with the elected officials (see credit 

criterion 5).

(c) Propose an update process for the substantial damage management plan 

and/or schedule. Consideration should be given to updates to the plan any 

time it is used after a flood or other hazardous event. 

(d) Note, in the implementation section, any steps that must be taken to adhere to 

the Privacy Act or any state or community privacy requirements.

(4) The community must prepare an annual evaluation report for its substantial damage 

management plan. The report must review the pre-event action items, describe what was 

implemented (or not implemented), and recommend changes to the action items as 

appropriate. It should highlight any flood damage that occurred since the development 

of the plan or since the previous annual evaluation. Updated substantial damage 

management plans can meet the annual evaluation requirement. 

The annual evaluation report or an updated substantial damage management plan should 

note any changes to the community’s regulations that affect substantial damage or 

substantial improvement (e.g., the definition of cumulative substantial damage or 

substantial improvement).

(5) The substantial damage management plan and the annual evaluation report must be 

submitted to the community’s governing body. If private or sensitive information (such 

as names or street addresses) is included in the report, then a summary report(s) must be 

prepared for the governing body, committees, media, and the public.
Addendum to the 2017 CRS Coordinator’s Manual A-60 Edition: 2021 

(6) The community must provide its latest update or revision to its substantial damage 

management plan in time for each CRS cycle verification visit. The update or revision

must include a review of each of the six planning steps. 

(7) The substantial damage management plan must be made available to the State NFIP 

Coordinator and the FEMA Regional Office, if requested.

Credit Points for SDP 

SDP = SDP1 + SDP2 + SDP3, up to the maximum of 140

SDP1 = 40 points, for a substantial damage management plan

SDP2, = 50 points, if FEMA’s Substantial Damage Estimator is 

pre-populated

SDP3 = 50 points, if pre-event mitigation alternatives are 

considered

Impact Adjustment for SDP

There is no impact adjustment for SDP credit. 

Documentation for SDP Provided by the Community

(1) At each verification visit,

(a) A copy of the substantial damage management plan (see Section 512.d) or, if the 

community is already receiving credit for a plan, a copy of the latest update or 

revision to the plan (see Step 6).

(b) A description of when and how the substantial damage management plan was shared 

with local officials.

(2) With the annual recertification,

(a) A copy of the annual evaluation report (or updated substantial damage management 

plan) and the date that it was shared with the elected officials.

NOTE: Failure to submit the evaluation report for the substantial damage management 

plan with the annual recertification or the update at the next cycle verification visit will 

result in loss of the credit (i.e., SDP = 0). 
Addendum to the 2017 CRS Coordinator’s Manual A-61 Edition: 2021 

Related Updates and Clarifications

 Under Credit Points for FMP Step 5 on page 510-16, subsection (b) is clarified by 

replacing it with this: 

(b) 25 points, if the plan includes a description of the impacts that the hazards identified in 

the hazard assessment (Step 4) have on the features listed below:

(1) 10 points, for life safety and public health (e.g., the need for warning and 

evacuating residents and visitors and considering health hazards to individuals 

from flood waters and mold).

(2) 5 points, for critical facilities and infrastructure.

(3) 5 points, for the community’s economy and major employers.

(4) 5 points, for the number and types of affected buildings (e.g., residential, 

commercial, industrial, with or without basements, etc.). For this credit, the 

assessment must include an inventory of all buildings owned by the community 

that are located in flood-prone areas and that identifies which buildings are 

insured for flood damage.

 Under For More Information on page 510-37, new sources for information about 

floodplain species and about substantial damage are inserted as follows:

e. Guidance, website links, and examples of floodplain species assessments can be 

obtained from a community’s ISO/CRS Specialist.

f. Substantial Improvement/Substantial Damage Desk Reference (FEMA P-758) (2010)

offers guidance on substantial damage provisions and management at the federal, state, 

and local levels, and discusses the variations among many building codes.

g. Explanations for working with the Substantial Damage Estimator can be found in 

Substantial Damage Estimator User Manual and Field Workbook (FEMA P-784) (2017).

h. Guidance on populating the Substantial Damage Estimator and using community data 

can be found in FEMA’s Substantial Damage Estimator Best Practices (2017).

i. FEMA’s Key Topics Bulletin, Mitigation Planning and the Community Rating System

(2018), aligns the CRS planning process with the required hazard mitigation planning.

j. FEMA’s Emergency Management Institute (EMI) offers independent and online training 

on substantial damage and substantial improvement. The course numbers and names are 

listed below. The State NFIP Coordinator may also offer training for communities.

Preparing for Post-Disaster Responsibilities (G0194.4)

Advanced Floodplain Management Concepts III (G0284)

Substantial Improvement/Substantial Damage (G0284.5)

Using the Substantial Damage Estimator 2.0 Tool (IS0284)

Substantial Damage Estimation for Floodplain Administrators (IS0285).
Addendum to the 2017 CRS Coordinator’s Manual A-62 Edition: 2021 

Addendum to

Activity 610 (Flood Warning and Response)

of the CRS Coordinator’s Manual, 2017 Edition

Summary

The changes to Activity 610 are clarifications to the language in the Coordinator’s 

Manual, inserts to account for updated technology, and additions to incorporate a 

community’s management of substantial damage assessments and post-disaster teams.

Updates and Clarifications

 Under 611 Background on page 610-2, the second paragraph is clarified with this 

replacement:

The National Weather Service (NWS) issues specific flood warnings for many locations along major 

rivers and coastlines. A community’s ability to receive notifications 24 hours a day and 365 days a 

year is crucial to using such warnings. Many communities have their own flood threat recognition 

systems to enable advance identification of floods on smaller rivers and streams. The full benefit of 

early flood warning is only realized if the community disseminates the warning to the general 

public and to critical facilities and has a flood warning and response plan that includes appropriate 

tasks, such as directing evacuation, sandbagging, moving building contents above flood levels,

performing damage assessments to provide data for community databases on cumulative damage

and substantial improvements, and procedures for post-flood permitting and recovery.

 Under 611.b Activity Credit Criteria, where the section continues on page 610-5, 

subsections (a) and (b) are replaced with the following:

(a) Describe the methods and warning devices used to disseminate emergency warnings to 

the general public that are credited under EWD. Studies have shown that flood damage 

can be reduced by 30% if people have 24 hours of warning during which to prepare for 

an event;

(b) Include specific flood response actions that are taken at the different flood levels or 

flash-flood-impact areas that are credited under FRO. This correlates the identified 

flood levels with emergency evacuation/rescue planning tasks, such as 1-foot depth—

evacuate foot traffic; 2- or 3-feet depth—high-water vehicles only; 4- to 6-foot 

depth—boat evacuation; over 9 feet—helicopter evacuations on call; and
Addendum to the 2017 CRS Coordinator’s Manual A-63 Edition: 2021 

 Under 611.b Activity Credit Criteria, where the section continues on page 610-6, 

subsections (d)(v) and (vi) are replaced with the language below, and a new 

subsection (vii) is added:

(v) The community must provide verification that the community participated in a 

drill/exercise or an actual activation of the plan within the past 12 months. This 

can be in the form of an after-action report/improvement plan or a similar 

“lessons-learned” report.

(vi) If EWD credit was provided for a warning system or systems, then the 

community must provide verification that the community tested those systems 

within the past 12 months. For EWD9 credit, the community must verify the 

facilities within its jurisdiction that meet this criterion.

(vii) If credit was provided for FRO4 in the parent plan, the community must 

provide verification of the special-needs population within its jurisdiction.

 Under 611.b Activity Credit Criteria, where the section continues on page 610-7, the 

fourth sentence in subsection (6) is clarified. Subsection (6) is replaced with this:

(6) There must be at least one exercise and evaluation of the flood warning and response plan 

each year that is compliant with the National Incident Management System (NIMS). This 

process is described in the Homeland Security Exercise Evaluation Program. The exercise 

can be for a flood, levee failure, dam failure, or hurricane. This criterion can be met if the 

plan is implemented in response to an actual flood-related event or threat of a levee failure. 

In either case, there must be an evaluation of the performance of the plan and 

recommendations for needed change, as is usually documented in an after-action report/

improvement plan. This criterion is part of the national emergency preparedness cycle.

 Under Documentation for FTR Provided by the Community on page 610-10, 

subsections (1)(iv) and (v) are replaced with the following:

(iv) A description of the flood threat recognition system. The description must 

identify the rivers, streams, and coastal floodplains for which flood stage 

forecasts are prepared and each forecast point. If the community has its own gage 

system, such as an ALERT system, the description must include the locations of 

the stream and precipitation gages. For communities whose states have a webbased flood alert system or portal, the URL to the website and other information 

needed to gain access.

(v) If the community has its own gage system, such as an ALERT system, a copy of 

the maintenance procedures for the system and records showing that the system 

is being maintained. This also applies to any other interoperable flood sensors 

that the community owns and operates, such as those purchased through the 

Department of Homeland Security’s Flood Apex Program.
Addendum to the 2017 CRS Coordinator’s Manual A-64 Edition: 2021 

 Under 612.c Flood Response Operations on page 610-15, the fourth paragraph, 

beginning “Flood warning and response . . .” is updated with this paragraph:

Flood warning and response planning must identify every opportunity to prevent loss of life 

and property damage during a flood. Using information from the flood inundation maps, the 

planning team should think about how flooding would occur—what areas will be affected 

and when. The team may refer to a database of repetitive loss structures or a tracking 

system for cumulative substantial improvement and/or substantial damage. This may 

include pre-populating FEMA’s Substantial Damage Estimator with local data. Through this 

brainstorming, the team can decide what actions, resources, and training will be needed. 

The office of the State NFIP Coordinator may be included in training and recovery 

procedures.

 Under Credit Criteria for FRO on page 610-16, subsection (3) is replaced with the 

following, to incorporate a community’s focus on substantial damage assessment:

(3) Bonus credit is provided under FRO5 if there is a list of the personnel, equipment, facilities, 

supplies, and other resources needed to complete each task. For full credit the list must

identify what is available within the community and what is needed from private suppliers 

or other jurisdictions.

 Under Credit Points for FRO on page 610-17, the formula for FRO2 is revised to 

distinguish between estimates of needed personnel and time required and to 

account for a disaster response team. The formulae for FRO3 and FRO4 are 

unchanged. The new formula for FRO2 reads:

Credit Points for FRO

FRO2 = the sum of the following:

(a) 5 points, for identified flood response tasks and

responsible staff,

(b) 5 points, for an estimate of the number of personnel

needed for each task, 

(c) 5 points, for an estimate of the time required for each

response task,

(d) 10 points, for damage assessment tasks that are tied into 

a cumulative damage/improvement tracking system,

(e) 5 points, for identification of a floodplain management 

disaster response team,
Addendum to the 2017 CRS Coordinator’s Manual A-65 Edition: 2021 

(f) 5 points, for a list of equipment and supplies expected 

to be needed and how they will be obtained

 Under Credit Points for FRO where it continues page 610-18, the formulae for FRO5

and FRO6 are revised for clarification:

FRO5 = the sum of the following, up to 15 points: 

(a) 5 points, if the plan includes instructions for an evacuation plan that addresses critical facilities, homes, and

businesses, with instructions for when and how returning

evacuees can reoccupy in compliance with the community’s SFHA permitting policies;

(b) 5 points, if the plan includes instructions for substantial

damage assessment procedures within the SFHA that 

are made before issuance of a permit during the 

recovery phase; and 

(c) 5 points, if the plan includes instructions for 

implementing the community hazard mitigation plan’s 

identified flood loss mitigation measures on community 

and private properties.

FRO6 = Up to 20 points, if the plan identifies actions that support

property protection measures that are carried out in both

the response and recovery phases.

 In Example 612.c-1 on page 610-18, the paragraph for FRO5 is revised to account for 

substantial damage assessments:

FRO5 Instructions for the return of evacuees to affected areas are also in the 

plan, including credential instructions and area security assignments. 

Substantial damage assessments are prescribed before repair permits can 

be issued. [10 points, partial credit under FRO5]