THE DISTRICT OF COLUMBIA COMMUNITY RATING SYSTEM PROGRAM REVIEW

Transcription

1 ANALYSIS REPORT: THE DISTRICT OF COLUMBIA COMMUNITY RATING SYSTEM PROGRAM REVIEW WRITTEN BY: Shana Udvardy and French Wetmore SEPTEMBER 30, 2014 Dialogue. Insight. Solutions.

2

3 i The District of Columbia Community Rating System Program Review Contents Acknowledgements... iii Executive Summary... iv 100 Introduction... 1 Background... 1 The CRS Costs and Benefits Procedures Program Prerequisites a. Program Data Table Application Procedures Credit Calculation Public Information Activities Elevation Certificates Map Information Service Outreach Projects Hazard Disclosure Flood Protection Information Flood Protection Assistance Flood Insurance Promotion Mapping and Regulations Impact Adjustment Map Floodplain Mapping Open Space Preservation Higher Regulatory Standards Flood Data Maintenance Stormwater Management... 39

4 ii 500 Flood Damage Reduction Activities Repetitive Loss Areas Flood Management Planning Acquisition and Relocation Flood Protection Drainage System Maintenance Warning and Response Flood Warning and Response Levees Dams Community Classification Calculations County Growth Adjustment Community Total Points Appendices Appendix A. Acronyms Appendix B: Summary of Recommendations... 62

5 iii Acknowledgements This paper was written for the District of Columbia by Shana Udvardy (Climate Adaptation Policy Analyst, CCAP), with support from French Wetmore (President, French & Associates, Ltd.). Phetmano Phannavong (Environmental Engineer) and Kyle Gasser (Intern) of the District Department of Environment provided guidance and contributions. Much of the information in this paper came from interviews with the following agencies. We are grateful for their help and input. DC Water District of Columbia Water And Sewage Authority DCAR DC Association of REALTORS DCHA DC Housing Authority DCOP District of Columbia Office of Planning DCRA Department Of Consumer and Regulatory Affairs DDOE District Department of the Environment DDOT District Department of Transportation DISB Department of Insurance Securities and Banking DPW Department of Public Works HSEMA Homeland Security and Emergency Management Agency DCAR OCTO Office of the Chief Technology Officer We would like to underscore our appreciation to the team at OCTO whose support and technical expertise was invaluable to the completion of this report: Tim Abdella, Mario Field, and Josh Lay. The views expressed in this paper represent those of the authors and not necessarily those of any of the other institutions or individuals mentioned above. For further information, please contact Shana Udvardy at (202) or French Wetmore at (253)

6 iv Executive Summary The Federal Emergency Management Agency (FEMA) established the Community Rating System (CRS) in 1990 as a voluntary program under the National Flood Insurance Program (NFIP). It is designed to reward a community s floodplain management activities that are above and beyond the NFIP s minimum requirements and that work toward the program s three primary goals: 1. Reduce and avoid flood damage to insurable property 2. Strengthen and support the insurance aspects of the NFIP 3. Foster comprehensive floodplain management If a community implements activities and submits the appropriate documentation to FEMA, then its residents can qualify for a flood insurance premium rate reduction. A community receives a CRS classification based upon the total score for its floodplain management activities. There are ten CRS classes: Class 1 requires the most credit points and gives the greatest premium reduction (45%) for flood insurance policies on properties in the floodplain mapped by FEMA (the Special Flood Hazard Area or SFHA ). A Class 10 community receives no premium reduction. A community that does not apply for the CRS, or does not obtain the minimum number of credit points, is a Class 10 community. During the summer of 2014, CCAP & French & Associates reviewed the District s activities to determine if it would qualify for the CRS and, if so, the level of credit for each series and the potential CRS class. CCAP & French & Associates collected the information presented in this report primarily from interviews with the District agency staff and District agency materials and District agency websites. FEMA provided flood insurance data. This paper summarizes their findings. Benefits of joining CRS There are multiple benefits to the District for joining and maintaining the CRS designation other than the reduction of the insurance premium for District residents. However, the fiscal savings are worth noting. If the District became a CRS class 7, policy holders in the mapped floodplain would save an average of $394 every year. The District as a whole would save over $105,000 each year in money that would not go to pay flood insurance premiums. In addition to the direct financial benefits to policy holders there are seven others worth noting: 1. The credited activities provide flood loss reduction, flood safety, and protection of natural floodplain functions benefits. 2. Credited activities that used to be done on an ad hoc basis will be better organized. 3. There is an incentive to keep implementing flood protection activities during dry years. 4. The District can evaluate the effectiveness of its flood program against nationally recognized benchmarks. 5. Technical assistance in designing and implementing a number of activities is available at no charge from the Insurance Services Office. 6. The public information activities help build a knowledgeable constituency interested in supporting and improving flood protection measures. 7. Every time residents pay their insurance premiums, they are reminded that the District is working to protect them from flood losses, even during dry years.

7 v Prerequisites There are six prerequisites that must be met for a community to join the CRS and an additional one to be a Class 6 or better. The District currently fulfills four of the six. The two remaining will take a level of effort: pass a Community Assistance Visit to be deemed fully compliant with the minimum requirements of the NFIP and complete certain steps to address repetitively flooded properties. Without meeting these two requirements, the District will not be able to join the CRS. Credited Activities FEMA provides CRS credits for a total of 19 activities organized under four series: Public Information; Mapping and Regulatory; Flood Damage Reduction; and Warning and Response. The series and corresponding activities are listed in the box to the right. For this report, CCAP & French & Associates reviewed each activity as it relates to current District efforts. For each of its elements, this report includes it objective, the current status in the District, and in most cases, recommendations on next steps. At the end of each activity is a summary table indicating the potential credits for the District, along with an estimated level of effort needed to attain the credits. The These tables are excerpted from an Excel file that is provided with this report. They are assembled as one table at the end in Section 720. This Excel format allows the District to determine and total the scores based on different scenarios. The totals for the activities in each of the four series are shown below. The levels of effort range from Now, i.e., nothing needs to be done to receive the credit, to Work, meaning the District would need some effort to start a new program or alter an existing program to become creditable. CRS Activities 300 Public Information Activities 310 Elevation Certificates 320 Map Information Service 330 Outreach Projects 340 Hazard Disclosure 350 Flood Protection Information 360 Flood Protection Assistance 370 Flood Insurance Promotion 400 Mapping and Regulatory Activities 410 Floodplain Mapping 420 Open Space Preservation 430 Higher Regulatory Standards 440 Flood Data Maintenance 450 Stormwater Management 500 Flood Damage Reduction Activities 501 Repetitive Loss Areas 510 Floodplain Management Planning 520 Acquisition and Relocation 530 Flood Protection 540 Drainage System Maintenance 600 Warning and Response 610 Flood Warning and Response 620 Levees 630 Dams District CRS Activities: Overview of Findings Series Activity Now Easy Work Max 300 Public Information Activities Mapping and Regulatory Activities 355 1, , Flood Damage Reduction Activities , Warning and Response activities County Growth Adjustment Column total 403 1,396 2,164 Potential CRS Class Series: With a little effort, the District would receive some credit under the public information series. With more effort, the public information credits could be increased through the preparation of a master Program for Public Information.

8 vi 400 Series: The District would receive credits for many of its mapping and regulatory activities without any further effort other than collecting or preparing some documentation. 500 Series: Additional work is needed for satisfactory scores under the 500 series of flood damage reduction activities. 600 Series: Additional work is needed for any scores under the 600 series of warning and response activities. Recommendations Based on the analyses of all of the series and corresponding activities and elements, CCAP and French & Associates have 49 recommendations on how the District can best meet the prerequisites and score well under the various activities. The bulk of the recommendations fall under the 300 series or Public Information Activities (23), followed by the 400 Series of Mapping and regulations (11). Appendix B has master list of the 49 recommendations under each series. Overall Findings and Recommendations 1. CCAP and French & Associates found that the District can participate in the Community Rating System without a great deal of effort if this report s recommendations are implemented: 2. The District must meet all the program prerequisites. Two prerequisites require new efforts by District offices: a. The District must be confirmed by FEMA as being in full compliance with the National Flood Insurance Program following a Community Assistance Visit (CAV). b. The District must implement certain activities that address properties that have received repetitive flood insurance claim payments. 3. District agencies must continue their current floodplain management activities. While it is an impressive milestone for the District to join the CRS Program, being in the program requires maintaining the CRS standards. To do this, the District must ensure that the right resources and policies are in place to support these agencies and their programs. 4. If the program s prerequisites are met, the District can obtain a CRS class 7 based on the activities currently implemented by the District staff plus a small effort to prepare and/or collect documentation needed to verify the credits. 5. With an increased level of effort identified in the various recommendations, the District could improve to a CRS class 6, 5, or 4 with increasing levels of effort. While a Class 4 is possible, a Class 5 or 6 would be more realistic. 6. The District needs to have an effective mechanism to manage the CRS aspects of the District s floodplain management program. The District needs to designate one person as the CRS Coordinator and provide that person with the authority to work with each of the affected agencies.

9 1 100 Introduction Background There are 22,000 communities in the National Flood Insurance Program (NFIP). Of these, 1,300 have programs that exceed the NFIP requirements and benefit from being the CRS. These 1,300 communities represent 6% of the NFIP membership, but 67% of all the flood insurance policies. They have found that the benefits of participation exceed the costs of joining. The 1,300 includes only a few large cities, most of them in the southeast where policy counts are high. In the Northeast, Boston, New York, Philadelphia, and Baltimore have voiced interest, but have not met the program s requirements (the nearest large cities in the CRS are Nashville, TN, and Charlotte, NC). The District of Columbia has been weighing the pros and cons of joining FEMA s CRS Program. There are benefits and there are costs to joining the program. During the summer of 2014, the District contracted with the Center for Clean Air Policy (CCAP) to review the District s activities to determine if it would qualify for the CRS and, if so, how well it would do. This report includes CCAP s findings and recommendations and is designed to help the District staff determine if the benefits outweigh the costs. The CRS The Federal Emergency Management Agency (FEMA) established the CRS in 1990 as a voluntary program under the National Flood Insurance Program (NFIP). It is designed to reward floodplain management activities that are above and beyond the NFIP s minimum requirements and that work toward the program s three primary goals: 1. Reduce and avoid flood damage to insurable property; 2. Strengthen and support the insurance aspects of the NFIP; and 3. Foster comprehensive floodplain management. Operation: If a community implements activities and submits the appropriate documentation to the Federal Emergency Management Agency (FEMA), then its residents can qualify for a flood insurance premium rate reduction. A community is a city or county, i.e., a local government with land use management authority. In this report, we may use community and the District interchangeably. A community receives a CRS classification based upon the total score for its floodplain management activities. There are ten CRS classes: Class 1 requires the most credit points and gives the greatest premium reduction (45%) for flood insurance policies on properties in the floodplain mapped by FEMA (the Special Flood Hazard Area or SFHA ). A Class 10 community receives no premium reduction. A community that does not apply for the CRS, or does not obtain the minimum number of credit points, is a Class 10 community. This information is summarized in Table from the CRS Coordinator s Manual, on the next page. The Special Flood Hazard Area (SFHA) is the area affected by the base, or 100 year, flood. The SFHA is mapped by FEMA and displayed on Flood Insurance Rate Maps (FIRM), the map that communities must use for their floodplain management regulations and the insurance industry uses for flood insurance premium rate setting. As noted in the Table 110 1, the discount benefit varies depending upon whether the property is situated inside or outside of the SFHA.

10 2 Community participation in the CRS is voluntary. Any community in full compliance with the rules and regulations of the NFIP may apply for a CRS classification better than Class 10. The applicant community submits documentation that shows that it is implementing the activities for which credit is requested. All CRS credit is verified during a visit conducted by the Insurance Services Office (ISO), which administers the CRS for FEMA. CRS Coordinator: Each community designates its CRS Coordinator, a staff member who coordinates with ISO and FEMA and assembles the needed explanatory materials from the various departments. The credit, documentation, and scoring criteria are spelled out in the CRS Coordinator s Manual. FEMA changed the program rules and procedures substantially with the publication of the 2013 CRS Coordinator s Manual. This updated manual can be downloaded at org. Recommendation 100.1: The District needs to have an effective mechanism to manage the CRS aspects of the District s floodplain management program. This is best done by designating one person as the CRS Coordinator and providing hat person with the authority to work with each of the affected agencies. Experience in other CRS communities, especially the larger ones, has shown the benefit of having a CRS Coordinator with the resources and authority needed to work effectively with other offices. Credited activities: CRS credit is provided for up to 19 creditable activities, organized under four categories of activities: 300 Public Information 400 Mapping and Regulations 500 Flood Damage Reduction 600 Warning and Response A number of CRS activities may be implemented by a private, state or regional agency rather than at the city level. What counts is that the activity is being implemented within the District or has an impact on flood losses in the District. Therefore, a city can receive credit for work that benefits local properties implemented by the State, the county, or even by private organizations. Particularly important for the District to note is that with a few exceptions, FEMA does not provide credit for activities implemented by other Federal agencies.

11 3 Maintaining eligibility: Once the District enters into the CRS Program, it will have to recertify that it is continuing to perform the activities that are being credited by the CRS. Recertification is an annual activity that includes progress reports for certain activities. A cycle verification takes place every five years for most communities and is conducted in the form of another verification visit. If a community is not properly or fully implementing the credited activities, its credit points, and possibly its CRS classification, is revised. A community may change its classification at any time by submitting a modification. The CRS and the District: Washington DC might be the only large city in the Northeast to gain CRS certification. However, there are a number of active CRS communities in Virginia and Maryland (22 and 13 respectively), ranging from Class 9 to Class 5. There are five smaller cities in Virginia that are in close proximity to the District with classifications that range from Class 8 to Class 6 (see table). 115 Costs and Benefits Area CRS Participation Community CRS Class Alexandria 6 Fairfax County 7 Falls Church 7 Arlington 8 Vienna 8 Costs: There are three components to the cost of participating in the CRS: 1. The cost of starting up a new activity, such as legal costs in drafting an ordinance; 2. The cost of implementing the activity; and 3. Direct CRS costs, such as collecting documentation and similar work, that is not considered a normal part of implementing an activity. It is assumed that the District feels the costs for its current activities are worth the benefits, so continuing to implement an activity should not be considered a CRS cost. Therefore, the only true cost of the CRS is the third, the direct cost of documentation not already done for an activity and the time spent with ISO and FEMA on the CRS. Benefits: The flood insurance premium discount is only one of many benefits of participating in the CRS, but it is the one most often queried. The potential discounts for the District are shown in the table on the next page. The table indicates that while there are 2,432 flood insurance policies in the District, 1,405, or 58% of them are Preferred Risk Policies (PRPs). PRPs are sold for properties outside the Special Flood Hazard Area and that have only had one small claim payment. PRP properties are considered relatively safe from flood damage and therefore have a relatively low flood insurance premium. Because of this, they do not receive a CRS discount on their premiums. The largest beneficiaries of the CRS discount are properties in the SFHA. Most CRS activities directly affect flood losses in the floodplain, so most of the benefits accrue to those properties. If the District became a CRS class 7, those policy holders would save an average of $394 every year. The District as a whole would save over $105,000 each year in money that would not go to pay flood insurance premiums.

12 4 In addition to the direct financial reward for participating in the Community Rating System, there are many other reasons to join the CRS. As FEMA and ISO staff often say, if you are only interested in saving premium dollars, you re in the CRS for the wrong reason. There are important additional benefits: 1. The credited activities provide flood loss reduction, flood safety, and protection of natural floodplain functions benefits. 2. Credited activities that used to be done on an ad hoc basis will be better organized. 3. There is an incentive to keep implementing flood protection activities during dry years. 4. The District can evaluate the effectiveness of its flood program against nationally recognized benchmarks. 5. Technical assistance in designing and implementing a number of activities is available at no charge from the Insurance Services Office. 6. The public information activities help build a knowledgeable constituency interested in supporting and improving flood protection measures. 7. Every time residents pay their insurance premiums, they are reminded that the District is working to protect them from flood losses, even during dry years. District Flood Insurance Premium Discounts for Different CRS Classes Data as of September 27, 2014

13 5 200 Procedures This section covers the prerequisites and procedures for applying for a CRS classification and the steps for calculating and verifying a community s CRS credit. It also covers annual recertification, modifications to the community s CRS credit, and cycle verification. 211 Program Prerequisites The District must meet the current CRS Coordinator s Manual s prerequisites at the time of each verification visit. An initial verification visit is conducted in response to a community s request to join the CRS. Subsequent visits are conducted every few years on a set schedule and are called cycle verification visits. 211.a Class 9 Prerequisites In order to become and continue to be a Class 9 or better, the District must demonstrate that it has enough points to warrant the class AND meet the following six prerequisites. 1. The District must have been in the Regular Phase of the National Flood Insurance Program (NFIP) for at least one year. Status: The District has met this prerequisite. 2. The District must be in full compliance with the minimum requirements of the NFIP. There must be correspondence from the Regional Office of the Federal Emergency Management Agency (FEMA) stating that the community is in full compliance with the NFIP. The correspondence must have been sent within six months of the initial CRS verification visit. The FEMA Regional Office will likely conduct a Community Assistance Visit (CAV). Status: This prerequisite is usually the hardest for communities to meet. FEMA Region III intends to conduct a CAV in FEMA staff will tour the regulatory floodplain and will review development permit records, especially Elevation Certificates. If the CAV finds problems, the CRS application will be delayed until they are rectified. Recommendation 211.1: The best preparation for the CAV is a review of all permit records and procedures before the visit. The District s procedures look good (see flow chart, page 13), however it is not clear if they are always followed. We recommend that the District adopt an MOU or similar agreement with the agencies involved to ensure effective and consistent implementation of the procedures. 3. The District must maintain FEMA Elevation Certificates on all new buildings and substantial improvements constructed in the Special Flood Hazard Area (SFHA) after the community applies for CRS credit. Status: See the discussion in Activity 310 (Elevation Certificates) of this report. 4. If there are one or more repetitive loss properties in the District, the District must take certain actions as specified in Sections Status: See the discussion in Section 501 of this report.

14 6 5. The District must maintain all flood insurance policies that it has been required to carry on properties owned by the District. The District s chief executive officer (CEO) signs the verification visit cover sheet, which includes a statement that the signer certifies that the community has all the flood insurance policies that it has been required to maintain on properties owned by the community. Status: For the District, the Mayor is the CEO. Recommendation 211.2: With GIS support, all District buildings in the SFHA should be identified. The CRS Coordinator should check the insurance coverage of those buildings in the SFHA. 6. The sixth prerequisite only affects coastal communities with Flood Insurance Rate Maps that show the Limit of Moderate Wave Action (LiMWA). The District s FIRM does not have a LiMWA. 211.b. Class 6 Prerequisites In order to be a Class 6 or better, a community must demonstrate that it has enough points to warrant the class AND meet the following two prerequisites. 1. The community must meet all the Class 9 prerequisites. Status: See the discussion above on the six Class 9 prerequisites. 2. The community must have received and continue to maintain a classification of 5/5 or better under the Building Code Effectiveness Grading Schedule (BCEGS). Both BCEGS classifications (residential/ personal and commercial) must be a class 5 or better. Status: BCEGS is a voluntary program. The Insurance Rating Office sends communities a questionnaire and then conducts a visit. The District has not completed a questionnaire in the past. The Department of Consumer and Regulatory Affairs would need to participate in the program and receive a classification of 5/5 or better to meet this prerequisite. A meeting with ISO s BCEGS staff is pending for late October. Recommendation 211.b.1: After the October meeting, DDOE and DCRA should determine if and when they can provide all that is needed for a BCEGS classification.

15 7 213a. Program Data Table Another prerequisite at application time is a CRS Program Data Table with lines 6 and 13 completed. A copy of the table appears below. The information for the two entries was obtained from the Office of the Chief Technology Officer (OCTO). At the first annual recertification after the District enters the CRS, OCTO and DCRA staff will need to complete the entire table and then update it for each recertification after then. DDOE, as the Floodplain Administrator and DC NFIP Coordinator provides annual reports to the District Council that have included the type of data needed for keeping the Program Data Table up to date each year.

16 8 212 Application Procedures An application for a CRS classification is voluntary. The District can request a CRS classification at any time. The District can request a CRS classification for any activities and elements, provided that: The credit points add up to at least 500 points, enough to become a Class 9; and The District can meet all of the Class 9 prerequisites (Section 211.a) The following documentation is needed to request a CRS classification. Both items can be submitted digitally to NFIPCRS@ISO.com (letters needing signatures should be scanned and sent as PDF files). 1. A letter of interest, signed by the Mayor that: a. States that the District is interested in joining the CRS, b. Designates the District s CRS Coordinator, c. States that the District will cooperate with the verification process, and d. States that the District understands that approval from the FEMA Regional Office is needed for the ISO/CRS Specialist to visit the community and verify the creditable activities Status: The CRS Coordinator would need to draft a letter for the Mayor with the above four elements when all the District agencies and materials are ready. 2. Documentation showing that the District is implementing activities that warrant at least 500 points. Status: This report can be used to provide this information. 220 Credit Calculation Activities: There are 19 activities that are credited by the CRS. The activities are organized under four series and numbered according to their sections in the CRS Coordinator s Manual. They are displayed in the box on the next page. Element scores: Within the activities, there are one or more elements. These are discrete pieces of a community s floodplain management program, and each receives a certain number of credit points. The bulk of this report reviews how the District would score under each relevant activity and element. Credit criteria: Each element has certain prerequisites that must be met to qualify for the credit. In some cases, there are activity credit criteria that apply to all the elements in the activity. Impact adjustment: The impact adjustment is a computation that modifies an element s points to reflect how much of its flood problem is affected by the activity. For example, a community that has preserved large portions of its floodplain as open space should receive more credit than one that is allowing most of its floodplain to be developed. All communities with open space start with the same number of points, but the points are adjusted to reflect the percentage of their floodplains that is kept in open space.

17 9 Several activities have no impact adjustment because the type of activity is assumed to cover the entire floodplain or the entire community. For example, most of the public information programs can reach and benefit all residents in the community. The District s Scores: At the beginning of the discussion of each activity is a table showing the expected points after the impact adjustment. An example for Activity 330 (Outreach Projects) is below. The last four columns refer to different levels of effort needed to obtain points: Now: The credit could be provided based on what the District is currently doing. Some effort may be required to document the current activities. Easy: Credit that could be obtained without a great deal of effort. Work: Credits that would require the District to start new programs or incur a new expense to implement an activity. Max: the maximum possible number of points for the element. CRS Activities 300 Public Information Activities 310 Elevation Certificates 320 Map Information Service 330 Outreach Projects 340 Hazard Disclosure 350 Flood Protection Information 360 Flood Protection Assistance 370 Flood Insurance Promotion 400 Mapping and Regulatory Activities 410 Floodplain Mapping 420 Open Space Preservation 430 Higher Regulatory Standards 440 Flood Data Maintenance 450 Stormwater Management 500 Flood Damage Reduction Activities 501 Repetitive Loss Areas 510 Floodplain Management Planning 520 Acquisition and Relocation 530 Flood Protection 540 Drainage System Maintenance 600 Warning and Response 610 Flood Warning and Response 620 Levees 630 Dams Activity Elements Now Easy Work Max 330 a OP Outreach projects b FRP flood response projects c PPI Program for Public Information d STK Stakeholders In this example for Activity 330 (Outreach Projects), the current District program would receive 10 points. It would not take much work ( easy ) to earn 20 more points. With a larger effort, which is explained in the section on Activity 330, the District could max out on the credit points for this activity. These tables are excerpted from the Excel file that is provided with this report. They are assembled as one table at the end in Section 720. This Excel format allows the District to determine and total the scores based on different scenarios. Such work can help determine what effort would be needed to reach the next CRS classification.

18 Public Information Activities The CRS credits local activities that advise people about the flood hazard, flood insurance, and flood protection measures. The activities can be directed toward floodplain residents, property owners, insurance agents, real estate agents, or other segments of the local populace. One activity, 310 (Elevation Certificates), is mandatory for CRS classification. 310 Elevation Certificates CRS Activities 300 Public Information Activities 310 Elevation Certificates 320 Map Information Service 330 Outreach Projects 340 Hazard Disclosure 350 Flood Protection Information 360 Flood Protection Assistance 370 Flood Insurance Promotion Objective: to maintain correct FEMA Elevation Certificates and other needed certifications for new and substantially improved buildings in the Special Flood Hazard Area (SFHA). 312.a. Maintaining Elevation Certificates (EC) This element is mandatory for participation in the CRS. For this credit, the District must collect and maintain a FEMA Elevation Certificate (FEMA Form 81 31) for all new and substantially improved buildings constructed in the SFHA. If a nonresidential building is floodproofed, a FEMA Floodproofing Certificate (FEMA Form ) must be collected and maintained. A separate Elevation Certificate is not needed for floodproofed buildings. The certificates must be reviewed to ensure that the information is correct. To be correct, a form must have all items on the CRS checklist complete and correct. The Elevation Certificate checklist is on pages and of the CRS Coordinator s Manual. Certificates can be provided in paper or digital format. Certificates on detached garages and nonsubstantial improvements are not needed for this activity s credit. During the cycle verification visit, the ISO/CRS Specialist will review the District s certificates using the checklist. The Specialist will provide the District with a summary of the review. To maintain the District s eligibility to stay in the CRS, at least 90% of the certificates must have not have any problems. If the District does not make the 90% passing threshold, the District is able to correct certificates and resubmit them. Status: DDOE and DCRA have been requiring Elevation Certificates for some time. They have developed procedures to ensure that all new construction in the SFHA meet requirements. These procedures are summarized in the flow chart on the next page, which includes DCRA obtaining a final Elevation Certificate. However, it is not clear that these procedures are always followed.

19 11 Recommendation 310 1: The flow chart should be followed, but it needs one important addition it should be clear that a certificate of occupancy is not issued to the builder until a correct final Elevation Certificate (or Floodproofing Certificate, as appropriate) is provided. Recommendation 310 2: The District should identify one or 2 people to be Elevation Certificate experts. These people would use the CRS checklists and review every certificate to ensure that they are all correct. Recommendation 310 3: District staff should use the checklists to scrutinize every existing certificate collected over the last few years. This would: Verify the new procedures, Prepare for FEMA s review of the certificates during the CAV, Ensure good certificates in the future, and Provide credit under the next element. French & Associates can assist in this effort. DDOE DCRA Permit Review Flow Chart

20 b. Maintaining Elevation Certificates for post FIRM buildings (ECPO) and 312.c. Maintaining Elevation Certificates for pre FIRM buildings (ECPR) These two additional elements provide credit for having Elevation Certificates for buildings constructed before the District s entry into the CRS. ECPR is for having Elevation Certificates on buildings constructed before the District s first Flood Insurance Rate Map, which was on November 15, ECPO is for having them on buildings constructed since that date, but before the CRS application verification visit. Status: After reviewing this with District agency staff, it was concluded that it would be very difficult to find those old files. Therefore, no credit is proposed for these two elements. However, if Recommendation is pursued, those certificates that are collected and that pass the review could be submitted for a few points of credit. Level of Effort Because EC credit is for having correct Elevation Certificates from the date of the application on, at the time of application, the District can receive the full 38 points. The credit is the District s to lose at later verification visits if ISO finds certificates that are not correct. The best way to prevent this is for the District to ensure a process where all new certificates are reviewed by an expert (Recommendations and 310 2) and to review existing certificates to identify common problems and surveyors who need special attention (Recommendation 310 3). Activity Elements Now Easy Work Max 310 a EC Elevation Certificates b ECPO Post-FIRM Certificates 48 c ECPR Pre-FIRM Certificates Map Information Service Objective: to provide inquirers with information about the local flood hazard and about flood prone areas that need special protection because of their natural functions. This activity credits providing Flood Insurance Rate Maps (FIRMs) and other maps in response to requests from the public. For this credit, the District s program must meet ALL of the following credit criteria: 1. MI1, providing information from the FIRM needed to write a flood insurance policy, is a prerequisite to receiving other credit under this activity. 2. The map information service must be able to locate a property based on a street address. 3. The information must be volunteered when there is an inquiry. For example, an inquirer about a property that is located in a Special Flood Hazard Area (SFHA) needs to be told about the mandatory flood insurance purchase requirement. 4. The service must include an opportunity for personal contact. 5. The inquiry must be responded to within a reasonable amount of time. 6. The service must be publicized at least once a year. There are three publicity options:

21 13 a. An annual notice that reaches everyone in the District, such as an article in a newsletter or a stuffer in a utility bill that goes to all properties; b. An annual notice directed to the most common users of the service: lenders (banks, credit unions, etc.), insurance agents, and real estate agents; and c. An annual outreach project developed as part of a Program for Public Information (PPI). 7. The maps used for MI1 and MI2 must be kept updated at least annually to reflect new studies, subdivisions, annexations, flood insurance restudies, map revisions, and map amendments. 8. The District must maintain copies of earlier FIRMs that have been in effect since It is recommended that the District keep a copy of every FIRM that has been published (credit for this is available under Activity 440 (Flood Data Maintenance)). 9. Records of the service must be kept and provided for credit documentation. Normally this is done with a log or a form letter that is completed when the information is provided. Status: The District has a map information service on line at that meets credit criteria 1, 2, 5, and 7. To obtain credit for Activity 320, the District would need to meet the credit criteria for the following elements. 322.a. Basic FIRM information (MI1) MI1 credits providing basic information found on a FIRM that is needed to accurately rate a flood insurance policy. If the property is in an SFHA, the District must inform the inquirer of the mandatory flood insurance purchase requirement, as appropriate. This may be done by advising the inquirer that flood insurance may be required because of the property s location or by providing a written summary of the requirement. Status: By meeting the Activity credit criteria described above, the District will qualify for MI1 credit. Not all the required information is provided on line, but the notice that people can call someone will be sufficient, provided someone will provide additional information from the District s FIRM, such as base flood elevations for a site. Having the website automatically send an inquirer a copy of the flood insurance study or map would not qualify, as one of the reasons for this credit is to help people who cannot read maps. Recommendation 320.1: The current web page has a notation that reads Note: Flood insurance is required for all insurable structures if you have a federally regulated mortgage. This should be slightly reworded and augmented with a link that provides more information about the mandatory purchase requirement to ensure meeting credit criterion 3. Recommendation 320.2: The District should post a notice on the map information web page stating who citizens can call if the user has questions (credit criterion 4). Recommendation 320.3: The District should publicize the map information web page by either an annual notice mailed to all properties (e.g., in a utility bill such as the DC Water bill) or an annual notice to the three main user groups (credit criterion 6). Recommendation 320.4: It is likely that the District has copies of the needed maps, but this needs to be confirmed (credit criterion 8). See also the discussion on having old FIRMs in Section 442.b.

22 14 Recommendation 320.5: DDOE, in concert with OCTO, should establish a mechanism for recording the public use of the web page (credit criterion 9). Recommendation The following changes are recommended for full credit and to remove some inappropriate items: a. The word determination should be deleted from the references to the service. Map determination is a technical term in the National Flood Insurance Program that refers to deciding if a bank loan requires a flood insurance policy. b. Section of the flood hazard areas ordinance sets a fee of $100 for Determination of a designated Zone in FIRMs for a given site or address and/or the Base Flood Elevation (BFE) if available. If the District charges fees this high, there would be no credit for this service. This language probably pre dates the website service. c. The website s FAQ How do I obtain information on flood zones? Found at should be updated to include all the information provided after the site is revised to qualify for these CRS credits. 322.b. Additional FIRM information (MI2) MI2 credit is for providing information that is shown on the District s FIRM that is not needed for insurance rating, i.e., whether the property in question is in the floodway, the coastal V Zones, or the Coastal Barrier Resources System. Status: The web page states whether the address is in a regulatory floodway. The floodway layer is accessible on the DC Atlas. This would warrant MI2 credit. 322.c. Other flood problems not shown on the FIRM (MI3) MI3 credit is for providing information about flood problems other than those shown on the FIRM. Note that providing information about historical flooding is credited under MI6. Status: The current program would not qualify for this credit. 322.d. Flood depth data (MI4) MI4 credit is for providing information about how deep flood waters can be anticipated to be in given areas of the District. The depth of expected flooding gives the inquirer a better concept of the flood hazard than does the base flood elevation alone. Status: OCTO staff report that such a map could be prepared. However, because the District can max out on the points for Activity 320 without this credit, there is no CRS urgency to do so. It would still be beneficial to have a flood depth map available for the public to use. 322.e. Special flood related hazards (MI5) MI5 credit is for providing information about special flood related hazards in the District. Status: There are no special flood related hazards in the District that would be credited. 322.f. Historical flood information (MI6) MI6 credits providing information about past floods that have occurred at or near the site in question. This could include mapped repetitive loss areas.

23 15 Status: As the District is required to map its repetitive loss areas, those areas could be posted for this credit. 322.g. Natural floodplain functions (MI7) MI7 credit is for providing information about areas that should be protected because of their natural floodplain functions. Status: OCTO staff report that they could add existing wetlands layers to the public website. Recommendation 320.7: Maximum credit is for MI1 plus three of the other elements, MI2 MI7. After discussions with District staff, it was decided that the best approaches for the maximum credit of 90 points for Activity 320 would be: MI2, with the concerns noted above resolved (20 points) MI6, showing repetitive loss areas after they have been delineated (see the discussion in Section 501). The delineation would not show which properties are on FEMA s repetitive loss list. (20 points) MI7, OCTO would include local wetlands delineations on the public web page. (20 points) Level of effort If the District implements the recommendations listed above, little effort is needed to max out on the credit for Activity 320 (90 points). The major effort needed is to tweak the public website to meet the credit criteria for MI1, which is a prerequisite for the rest of the credits. Once this is done, the other credits are listed as easy. Activity Elements Now Easy Work Max 320 a MI1 Reading the FIRM b MI2 Floodways c MI3 Other flooding 20 d MI4 Flood depth 20 e MI5 Special flood-related hazards 20 f MI6 Historical information g MI7 Natural areas Outreach Projects Objective: to provide the public with information needed to increase flood hazard awareness and to motivate actions to reduce flood damage, encourage flood insurance coverage, and protect the natural functions of floodplains. 332.a. Outreach projects (OP) This element is the basic credit using various media to disseminate floodplain management messages. To receive credit, projects must be disseminated at least annually. At least one project must convey a message on the topic of flood insurance. Note that there is additional credit for outreach projects that promote flood insurance under Activity 370 (Flood Insurance Promotion).

24 16 The maximum credit for this element is 200 points. If the community has a Program for Public Information (PPI) that discusses preparation and implementation of the project, it can receive up to 80 extra points. If the project is delivered by a stakeholder (STK), it can receive up to 50 additional extra points. Points are based on the type of project and the messages covered. Messages are scored under six general topics: Topics Example Messages 1. Know your flood hazard Your property is subject to flooding 2. Insure your property for your flood hazard Take advantage of a low-cost Preferred Risk Policy 3. Protect people from the hazard Turn around, don t drown 4. Protect your property from the hazard We can help you get a grant to elevate your home. Call us at 5. Build responsibly Get a permit before you build from. 6. Protect natural floodplain functions Report broken silt fences: they help keep our streams clean Status: There are several brochures available to the public at the DCRA permit counter (photo) and at other locations. These include: Flood Risk Management in the District of Columbia (would need to be updated to account for the changes under Biggert Waters and its amendments Guide to Stormwater Management & Erosion & Sediment Control Stormwater Management Credit Trading and RiverSmart Rewards The following items are currently on the website ( They could qualify as outreach projects, provided they are made available somewhere, e.g., at the permit counter: Floodplain Review Flow Chart Be Ready DC Family Emergency Preparedness Guide IT S A DISASTER!...and what are YOU gonna do about it? There are references to other materials, but the links are broken. If the District s website qualifies for credit under Activity 350 (Flood Protection Information), the materials on the site should be credited there because there are more points. If the website does not meet the credit criteria of Activity 350, then the materials will qualify for OP credit. The six items listed above are given a preliminary OP score in the table on the next page. The score can be increased significantly if the materials are placed in more locations, if other materials were provided and scored, and if new materials were prepared. Recommendation 330.1: Staff should inventory and collect projects that are currently implemented by organizations and agencies the serve the District, such as the Red Cross and HSEMA.

25 b. Flood response preparations (FRP) FRP credits developing a pre flood plan for public information projects that will be implemented during and after a flood. An FRP package is a collection of outreach projects prepared in advance, but not delivered until a flood occurs. These materials may include templates and masters of handouts, mailers, press releases, etc. that cover key messages that need to be disseminated before, during, and after a flood. The package must include both the materials that will be needed and the procedures for how they will be used. Status: The review of current programs did not identify any projects that would qualify. Recommendation 330.2: HSEMA should convert some existing materials to meet the FRP criteria. 332.c. Program for Public Information (PPI) The PPI is an ongoing public information effort to design and transmit the messages that the community determines are most important to its flood safety and the protection of its floodplains natural functions. Preparation of the program follows a seven step planning process, with support from a committee of local staff, stakeholders, and members of the public. This element is a 40% multiplier that increases the points for each OP and FRP project that is covered in the PPI. The maximum extra credit for this element is 80 points. Note that a PPI can help design an entire public information program, not just outreach projects. A PPI that covers other types of public information endeavors, such as a website and technical assistance, can result in increased credit under other activities. Status: The District does not have a committee that would meet the criteria at this time. However, there has been interest in organizing a public private committee to coordinate public information efforts. Recommendation District staff should determine if there is interest on the part of other District offices and private organizations in forming a committee and preparing a PPI. If so, there are additional guidance materials webinars available from FEMA and ISO.