types of non-reg products some communities may need, but that FEMA has so far not used.” A.2. Account for geologic/geomorphic hazards on flood maps, including fluvial erosion /channel migration zones. Channel migration zones have key relevance to endangered and threatened species habitat requirements, e.g. salmonids, as well as building safety. Putting all of the hazards on one traditional “FIRM” map isn’t practical. We should be presenting data, not maps. This comment can be included on most of these first recommendations. A.3. Include all hazards (erosion, , storm surge) on flood maps,. These should be based on current medium to high GHC scenarios. Current estimate of average U.S. residential structure life is 150 years. Also see L.3 Comment: should this specify a date rather than a number of years? A yearly update becomes necessary on a long project Modeling becomes very uncertain out to such a time period. It can also become confusing with the 100-year standard. Subsidence and seal level rise are not flood hazards and should not be ‘mapped’ however, subsidence and sea level rise should be taken into consideration when determining There is some concern with the uncertainty with this standard and that the use of this and the following language related to residential structures is unrelated to what may happen in the natural and build environments 150 years from now. hard to recommend a 150 year standard when we had a whole seminar on the 100 year standard, and determined keeping it was the best course of action. Honeycutt: Storm surge has been considered in FEMA’s coastal flood maps for >35 years. The Association should cease writing references like this (incl. in annual Goals & Objectives) that suggest it’s somehow missing from FEMA’s data. Several of us have tried to catch/correct this over the years, but it continues to pop up. Hillier: with Honecutt’s comment above. However, concerned with the absence of storm surge in this discussion. Edit below addresses both needs. Honeycutt: See comment on L.3 – 150 years is an arbitrary number, and may be inappropriate more often than not. Better to call for the use of site-specific hazard data that correspond to more realistic estimates of the useful lifetime of a resource or investment.
R.19. Establish strong federal floodplain management rules for federal investments and actions that are based on the principles of long term resiliency – including from climate change, use of natural ecosystems for resilience/sustainability and flood damage reduction. Environmental Defense Fund (EDF) has additional expertise and information such tools and can provide assistance. R. 20. sustained state and local flood hazard mitigation grant programs that can complement federal investments in hazard mitigation. Moved to H. 23. R. 21. Provide incentives (CRS, disaster relief and others) for all state and local managers to be CFMs. R. 22. Pass sufficient enabling authority for regions and communities to develop stormwater utilities or similar mechanisms that can provide resources for an array of flood risk management and loss reduction actions. This is a state issue. The feds cannot dictate or authorize local/regional utilities – stormwater or otherwise. R. 23. FEMA should develop and implement a type program to assist states in building state hazard mitigation capability. Clarify flood risk is not a federal responsibility Doesn’t this already exist? Should this move to H. Building State & Local Capability S.1. Support and provide incentives to states in efforts to encourage progressive state and local programs and activities, including NAI approaches (explore allowing states to participate in the CRS program) Question received: would this work since it is tied to a CIN? S.2. Develop procedures and implement the “managing state” concept Include a reference to the associated legislation UNCLEAR WHAT THIS IS REFERRING TO Recommendation to delete completely: This was piloted during the past year with 1 state per FEMA region. Addressed in H. Mitigation. S.3. Increase funding for federal programs that provide technical expertise that supports state mitigation strategies and the production of mitigation grant applications This is Risk MAP. Risk MAP can provide not only maps and depth grids, but also “Mitigation Planning Technical assistance” and “Mitigation Technical Assistance”. Perhaps an ASFPM recommendation should be that FEMA better define what these services are/should be, with the input of states, locals, ASFPM, etc.