Washington, D.C., November 30, 2023 – The SmarterSafer Coalition submitted the following comment letter to FEMA’s Director of Policy and Integration Division for the Office of Environmental Planning and Historic Preservation, Resilience, Portia Ross, expressing their enthusiastic support for the FFRMS proposed policy.
Dear Ms. Ross,
SmarterSafer is a national coalition made up of a diverse chorus of voices who champion environmentally responsible and fiscally sound approaches to natural catastrophe mitigation and the promotion of public safety. The coalition focuses on several policy areas, including flood and wildfire risk, extreme heat, infrastructure investment, environmental protection and conservation, and overall responsible stewardship of taxpayer dollars.
As advocates for resilient and sustainable approaches to flood risk management, the members of the SmarterSafer Coalition are pleased to offer our enthusiastic support for the proposed FEMA policy regarding the Federal Flood Risk Management Standard (FFRMS). This comprehensive initiative, as outlined in the Federal Register, is a commendable step towards fortifying the resilience of communities and Federal assets in the face of the increasingly pressing threats posed by flooding.
We commend FEMA’s initiative to develop a policy that intricately defines crucial aspects, including the determination of flood elevations and corresponding floodplains for actions subject to the FFRMS. The incorporation of methodologies such as the Climate Informed Science Approach (CISA), the Freeboard Value Approach (FVA), and the 0.2 Percent Annual Chance Flood Approach (0.2PFA) speaks to FEMA’s dedication to employing diverse and adaptive strategies in decision-making processes based on the best available scientific knowledge.
The proposed policy’s emphasis on utilizing the most pertinent, actionable hydrologic and hydraulic data, while integrating present and future changes in flooding based on climate science, is particularly praiseworthy. We fully support the approach that mandates a more stringent FFRMS floodplain for critical actions, which inherently enhances the level of protection against potential flooding scenarios. Additionally, we encourage FEMA to adopt the higher standard rather than the lower standard for non-critical actions, as well. Utilizing the higher standard for non-critical actions will provide additional protections and improve interagency alignment with the Department of Housing and Urban Development’s (HUD) FFRMS policy.
Moreover, we commend the policy’s provisions for identifying actions that might be subject to determinations of substantial damage or substantial improvement.
We recommend that FEMA prioritizes avoidance as the first alternative to actions that would modify or compromise floodplain function as the most effective risk reduction strategy. Where avoidance cannot be achieved, resilient design should be incorporated meaningfully. Additionally, encouraging the use of natural features and nature-based approaches as viable alternatives where possible aligns seamlessly with our coalition’s commitment to integrating innovative and sustainable solutions into flood risk management strategies.
The outlined requirements to minimize flood risk, combined with the call for early coordination among multiple Federal agencies involved in an action, signify a significant stride towards ensuring a consistent and harmonized approach in determining the applicable floodplain standards. This collaborative effort will undoubtedly foster stronger, more resilient communities while safeguarding vital Federal assets.
The SmarterSafer Coalition firmly believes that the proposed FEMA policy represents a critical step towards enhancing flood resilience in communities and protecting Federal assets. We endorse this proactive and approach and anticipate its substantial contribution to the overarching goal of mitigating flood risks in the United States.
Thank you for considering our strong support for this pivotal policy initiative. We eagerly anticipate the positive impact of this proposal in building a more resilient and sustainable future.
The SmarterSafer Coalition
Center for Climate and Energy Solutions (C2ES)
Defenders of Wildlife
National Wildlife Federation
Natural Resources Defense Council (NRDC)
The Nature Conservancy
Consumer and Taxpayer Advocates
Coalition to Reduce Spending
National Taxpayers Union
R Street Institute
Taxpayers for Common Sense
Taxpayers Protection Alliance
Insurer and Reinsurer Interests
American Property Casualty Insurance Association (APCIA)
Association of Bermuda Insurers and Reinsurers (ABIR)
Liberty Mutual Group
National Association of Mutual Insurance Companies (NAMIC)
National Flood Association
Reinsurance Association of America
Natural Hazard Mitigation Association
Habitat for Humanity
National Housing Conference
National Leased Housing Association
Allianz of America
American Conservation Coalition
American Consumer Institute
Center for Clean Air Policy
Friends of the Earth
Institute for Liberty
Zurich North America