Report of the 
Floodplain Management Forum 
June 8, 2000 
The Madison Hotel 
Washington, DC 
Sponsored by 
Federal Emergency Management Agency
Contents 
Foreword by James L. Witt 
Section One: Floodplain Management Forum Issue Paper………………………..1 
Section Two: Floodplain Management Forum Themes……………………………6 
Section Three: Floodplain Management Forum Minutes…………………………13 
Section Four: Floodplain Management Forum Statements………………………..41 
Appendix A: Participant List 
Appendix B: Agenda
Foreword 
The Floodplain Management Forum was held on June 8, 2000, in Washington, DC. A diverse 
group of floodplain management experts participated in the Forum and discussed the future of 
floodplain management in the United States. The Forum is part of a continuing process to 
increase the public dialog and develop strategies that better protect and enhance our Nation’s 
floodplains and reduce the costs of flood disasters. I commend the participants for an 
informative discussion and many thought-provoking recommendations and policy options. 
This report captures the major themes that were presented by the participants during the Forum. 
The themes present a challenge not only to the Federal Emergency Management Agency 
(FEMA) and other Federal agencies but also to State governments, community officials, and 
individual citizens. 
Since 1968 the National Flood Insurance Program’s floodplain management component has 
served as the Federal Government’s principal tool for realizing the better and wiser use of the 
Nation’s floodplains. Much progress has been made during the past 30 years in addressing the 
Nation’s flooding problems through those efforts. However, despite this progress, the number 
and severity of flood events and the costs of flood disasters continue to rise. To reverse this 
alarming trend, we must develop innovative strategies, implement improved incentives, and 
establish effective partnerships. We must broaden the focus from solely flood-loss reduction to 
the creation of sustainable communities and the protection of the natural and beneficial functions 
of floodplains. We should create and support comprehensive watershed solutions for reducing 
flood damage and protecting and restoring floodplains. 
We are all jointly responsible for managing our Nation’s floodplains. Governments must 
improve policies and programs to increase the capability of and reward individuals and 
communities that make wise land use decisions that encourage the building of sustainable 
communities. Government agencies must improve communication and coordination to establish 
a unified Federal effort in the shared goal of natural resource protection and restoration. 
However, regulatory standards and technical expertise from the Government will not be enough. 
There must be commitment and investment from communities, businesses, citizens, and other 
stakeholders to develop comprehensive watershed plans and implement sound floodplain 
management; to share responsibility and accountability for land use decisions that put people and 
property at risk to flooding; and to not solely rely on Federal disaster recovery assistance. We 
must recognize the natural and beneficial functions of floodplains and exploit the link between 
floodplain management and the economic sustainability and environmental quality within a 
community. Project Impact has shown that through collaborative partnerships and planning, we 
can create disaster-resistant communities while enhancing economic vitality and protecting 
environmental resources.
FEMA looks ahead to continuing the national dialog and collaboratively working together to 
achieve these goals. We will never move ahead as a Nation on these issues until we all move 
ahead together. 
James L. Witt 
Director 
Federal Emergency Management Agency
Floodplain Management Forum 1 
Section One Floodplain Management Forum Issue Paper 
The Floodplain Management Forum Issue Paper was written by FEMA and distributed to the 
participants prior to the Forum. This issue paper articulates the goals and objectives of the 
Forum and was designed to capture some of the floodplain management issues and guide 
discussion at the Forum. 
Background 
Floodplain management in the United States has undergone a significant change during the 
20th century. For more than the first half of the century, the Federal Government attempted to 
control floods through structural methods. This strategy proved unsuccessful as the cost of flood 
damage increased and the ecological integrity of the Nation’s watercourses were negatively 
impacted. Therefore, in 1968 the U.S. Congress created the National Flood Insurance Program 
(NFIP) to reduce the escalating costs of flood disasters that are borne by taxpayers. The NFIP 
marked a significant shift from traditional structural methods of flood control toward floodplain 
management and shared responsibility. Through the NFIP, all units of government, the private 
sector, and individual citizens share the responsibility for managing the Nation’s floodplains. 
In the past decade, considerable progress has been made in taking a more holistic approach to 
floodplain management. The concept of sustainability brings a relatively new approach to 
environmental, economic, and social thought. Sustainability is development that maintains or 
enhances economic opportunity and community well-being while respecting, protecting, and 
restoring the natural environment on which people and economies depend. 
Federal, State, and local units of government are now beginning to incorporate sustainability into 
floodplain management. It is widely understood that we cannot view floodplain management in 
a vacuum. To fully protect the natural integrity of floodplains and protect people and property 
from floods, we must integrate floodplain management into land use planning, economic 
development, habitat protection, flood insurance, cultural preservation, and many other locally 
driven activities. 
The NFIP currently provides significant protection against flood losses. The NFIP has saved an 
estimated $1 billion per year in flood damage, and has reduced flood damages to individual 
buildings by approximately 77 percent. Although the NFIP has reduced flood damage, the 
number and severity of catastrophic flood events and the costs of disasters continue to rise at an 
alarming rate. Riverine flood damage now exceeds $5 billion annually. 
Hurricane Floyd is the most notable recent example. The flooding caused by Hurricane 
Floyd approached or exceeded the 500-year flood in some areas, devastating properties and lives 
and disrupting many communities along the east coast of the United States. The damages from 
Hurricane Floyd are estimated to exceed $700 million. Moreover, a majority of the residents 
living inside and outside the special flood hazard area did not have flood insurance.
Floodplain Management Forum 2 
Despite the successes of the NFIP, many people continue to ignore flood risk and choose to build 
in the floodplain, perpetuating the continuous cycle of build-flood-rebuild. To break this 
disastrous cycle, Director Witt has worked tirelessly the past several years through the Project 
Impact initiative to encourage communities to identify hazards and take proactive steps to build 
sustainable and livable communities. Through Project Impact, community leaders from the 
public, private, and nonprofit sectors have coordinated their efforts to plan and implement 
activities designed to protect their communities against future disasters. Project Impact has 
taught us that through collaborative partnerships and planning, we can create disaster-resistant 
communities while protecting and enhancing environmental resources. 
Recent flood events such as Hurricane Floyd, increased urbanization of watersheds, coastal 
erosion, and climatic changes have brought to the forefront our Nation’s vulnerability to floods 
and the issues regarding the adequacy of NFIP requirements. Although the NFIP has made 
significant strides over the past 30 years, more must be done to reduce the threat that floods pose 
to the Nation’s economy and the safety of its citizens. We must evaluate the past successes and 
failures of the NFIP and, more importantly, develop new strategies to better identify the flood 
hazard risk, provide a higher level of protection against flood risks, cultivate a greater sense of 
responsibility and accountability, and encourage States and communities to foster sustainable 
development. 
Floodplain Management Forum 
The purpose of the Floodplain Management Forum is to bring together a select group of 
individuals with expertise and experience in floodplain management. The Forum will focus on 
the large issues facing the NFIP and floodplain management and began to explore methods to 
increase the level of protection against flood risks. This Forum will help the Federal Emergency 
Management Agency (FEMA) evaluate the NFIP to improve programs and policies and develop 
a future strategy for the NFIP. Certainly FEMA alone cannot foster sustainable development and 
sound floodplain management throughout the United States. It will take collaborative 
partnerships among all levels of government, the private sector, nonprofit organizations, and 
individual citizens. 
The Forum is designed to be a highly interactive discussion focusing on the future of the NFIP 
and floodplain management. It is important that the Forum identify aspects of the NFIP that are 
ripe for change, and issues that will require a more extensive national dialog to raise public 
awareness and support such changes. A concerted effort has been made to invite people who 
represent the diverse stakeholders of the NFIP, including representatives of academia, 
environmental groups, government agencies, the insurance industry, the building industry, 
lending institutions, local floodplain administrations, and elected officials so that a variety of 
viewpoints regarding the NFIP and floodplain management could be heard. 
Each participant is requested to provide a copy of his or her prepared statement prior to the 
Forum. A report will be developed and distributed to all the participants following the Forum. 
The report will capture the discussion generated at the Forum, the statements submitted by each 
participant, and the participant’s recommendations for implementing change. The report will be 
used by FEMA to consider changes or new initiatives regarding FEMA’s responsibilities in
Floodplain Management Forum 3 
administering the NFIP and other FEMA programs affecting the management of the Nation’s 
floodplains. 
The complex issues surrounding the NFIP equally involve the three intricately connected 
components of the program: flood hazard identification, floodplain management, and insurance. 
To develop a future strategy for the NFIP, we must examine these three components as a whole. 
To capture some of the issues and guide discussion at the Forum, we have developed a brief 
description of the three components of the NFIP followed by a list of policy questions. These 
policy questions are intended to highlight some of the issues; however, please do not limit 
yourself to these policy issues alone. 
Flood Hazard Identification 
Flood hazard identification is the backbone of the NFIP and is critical to managing development 
of the floodplain. FEMA produces Flood Insurance Rate Maps (FIRMs) that delineate the 
floodplain and regulatory floodway boundaries, base flood elevations, and insurance risk zones. 
FIRMs are an essential tool by which States and communities evaluate their flood risks to 
manage development in the floodplain, insurance agents properly rate flood insurance policies, 
and lending institutions and Federal agencies determine flood insurance requirements. For a 
community to make wise land use decisions, flood risk must be accurately identified. However, 
flood maps in many communities are inaccurate and outdated; some communities have never 
been mapped. 
In 1997 FEMA developed a Map Modernization Plan to provide communities with more 
accurate and extensive flood hazard maps. This aggressive 7-year plan is designed to update and 
digitize the 100,000-panel flood map inventory. Unfortunately, lack of funding has hindered the 
implementation of the Map Modernization Plan. 
Accurate flood hazard identification is essential for sound floodplain management and prudent 
flood insurance decisions. It is important that we better assess the flood hazard risk and provide 
communities with the most accurate and usable data. The following questions are intended to 
capture some of the policy issues surrounding flood hazard identification: 
· Should the mapping of floodplains be based on a higher standard, such as the 500-year 
standard? 
· How can the uncertainty in hydrology be addressed in the flood maps? 
· Should mapping be based on future conditions, accounting for urbanization and coastal 
erosion? 
· Does the current policy that recognizes levees or removes properties from the floodplain 
adequately reflect the flood risk? 
· Are hazards such as coastal erosion, alluvial fans, coastal flooding, high-velocity flooding, 
and similar hazards adequately addressed in the hazard identification and mapping?
Floodplain Management Forum 4 
· Are current standards for designating floodways appropriate, particularly the allowance of a 
1-foot increase in flood stage? 
· Are there methods of identifying flood hazards other than the traditional mapping approach? 
Floodplain Management 
All units of government, the private sector, and individual citizens share the responsibility for 
floodplain management. Federal and State Governments must develop policies, programs, and 
incentives that increase the capability of and encourage individuals and communities to foster 
sound floodplain management and sustainable development. Communities and individuals must 
accept more responsibility and accountability for land use decisions that put people and property 
at risk for flooding. 
We must take a holistic approach in managing our floodplains, begin to integrate floodplain 
management in land use planning and decisions, and move toward building disaster-resistant, 
sustainable communities. To achieve this goal, we must evaluate current NFIP regulations to 
determine whether they provide an adequate level of protection against flood risks. We also 
must develop innovative and creative methods to increase the capability of State and community 
floodplain management programs. The following questions are intended to capture some of 
policy issues surrounding floodplain management: 
· Should a higher standard, such as the elevation to the 500-year floodplain, be implemented? 
· Should freeboard be required above the base flood elevation (BFE)? 
· Are hazards such as coastal erosion, alluvial fans, coastal flooding, high-velocity flooding, 
and similar hazards adequately addressed in the regulatory requirements? 
· What strategies can be developed to encourage communities to adopt hazard mitigation plans 
or comprehensive plans and policies that steer development out of floodplains? 
· Are there other things the Program can do to increase levels of protection for flood-prone 
properties? 
· What strategies and incentives can encourage States and communities to foster sustainable 
development and discourage inappropriate floodplain development? 
· What can be done to instill a greater sense of responsibility in States, communities, and 
citizens for inappropriate floodplain development that puts people and property at risk? 
· What strategies can be developed to address the flood risk to structures constructed prior to 
the NFIP?
Floodplain Management Forum 5 
Insurance 
Flood insurance is an essential mechanism for transferring the costs of flood losses from 
taxpayers to property owners through flood insurance premiums. Flood insurance also 
encourages mitigation by providing rating and premium incentives and helps cultivate individual 
responsibility and accountability for floodplain land use decisions. More than 4 million flood 
insurance policies are in force, although they may cover fewer than one-third of those who need 
coverage, both inside and outside of high-risk areas. Since the passage of the National Flood 
Insurance Reform Act (NFIRA) of 1994, lender compliance with the mandatory purchase 
requirement has improved considerably; however, many mortgaged properties still do not have 
flood insurance. 
Through the Cover America I and II campaigns, the Federal Insurance Administration (FIA) is 
effectively marketing flood insurance and building a recognizable “Be Flood Alert” logo for the 
NFIP. Some flood insurance sales can be attributed directly to advertising, with the biggest 
impact in low- to medium-risk areas. Despite FIA’s efforts and successes, the market 
penetration of flood insurance has not reached desired levels. If the NFIP is to fully achieve its 
objectives, strategies must be developed that will increase the number of property owners who 
have flood insurance, both inside and outside of the special flood hazard area, and ensure that 
flood insurance policies do not lapse. The following questions are intended to capture some of 
the issues surrounding flood insurance: 
· Should the flood insurance Mandatory Purchase Requirement be extended to apply outside of 
the 100-year floodplain? Are there other ways to increase coverage in these areas? 
· Are there methods to improve implementation of the Mandatory Purchase Requirement by 
Federal agencies and lenders? 
· Are there ways to ensure that, once purchased, flood insurance policies remain in place? 
· Are there ways to increase insurance coverage to buildings not subject to the Mandatory 
Purchase Requirement? 
· Should flood insurance be required behind levees? 
· Is the current flood insurance rating model sufficient, or are there other methods to rate the 
flood risk?
Floodplain Management Forum 6 
Section Two Floodplain Management Forum Themes 
The Floodplain Management Forum brought together a diverse group of individuals with 
expertise in floodplain management. The goal of this Forum was to identify strategies to protect 
and restore our floodplains, improve flood hazard identification, reduce flood risks, and 
encourage communities to foster sustainable development. 
Each participant submitted a written statement and briefly articulated suggestions on the future 
of floodplain management. This section of the report captures the major themes that were 
presented by the participants during the Forum and in the participant’s written statements. The 
themes presented below do not necessarily represent the views of all the participants at the 
Forum or the views of FEMA. 
1. Shift the focus from flood-loss reduction to the creation of sustainable communities and 
the protection of the natural and beneficial functions of floodplains. 
A. Floodplain management must move beyond the narrow focus of flood-lo ss reduction and 
begin to focus on coordinated, multiobjective, watershed-based approaches that include 
the protection and restoration of the natural and beneficial functions of floodplains. 
B. Consider a no-adverse-impact approach to floodplain development. This means that no 
land use development in the watershed could adversely impact other property upstream 
or downstream, by increasing either flood elevations or flood velocities. The only 
exceptions would be based on requiring comprehensive local plans that ensure that all 
potential adverse impacts would be properly mitigated to avoid current and future flood 
damage. 
2. Continue to improve coordination among Federal agencies and create a framework for 
more effective Federal, State, tribal, and local coordination of floodplain management. 
Federal agencies must improve communication and coordination so that there is a unified 
effort to achieve the shared goal of natural resource protection and restoration. 
A. Reinstate the Federal Interagency Floodplain Management Task Force, which could 
serve as a coordinating entity for developing comprehensive strategies and improved 
Federal policies. 
B. Update the Floodplain Management Executive Order 11988, which establishes unified 
Federal policy regarding the protection of floodplains, to ensure that Federal agencies’ 
actions do not adversely impact floodplains. 
C. Continue to develop interagency Memorandums of Understanding (MOUs) to encourage 
uniform implementation of policies among Federal agencies.
Floodplain Management Forum 7 
D. Evaluate other Federal programs to ensure these programs do not have a negative impact 
on floodplains and are complementary to overall floodplain management objectives. 
E. Develop national standards for the design and placement of infrastructure. 
Infrastructure damages constitute a major portion of Public Assistance costs following 
disasters. 
F. The Federal Government should set an example by enforcing appropriate restrictions on 
floodplain land it leases to private individuals. 
G. FEMA should partner with the U.S. Geological Survey (USGS) to support the National 
Streamflow Information Program, which will improve flood forecasting, provide more 
timely assessment of flood characteristics, and assist in the development of new tools for 
improving flood inundation mapping and enhancing the flood information delivery 
system. 
3. Encourage and provide incentives for communities to develop master plans and hazard 
mitigation plans. 
A. Support and encourage local planning processes that reduce risk and protect and restore 
floodplains. FEMA should accept local mapping and local plans for management 
actions. FEMA and other Federal agencies should officially recognize these local plans. 
This would provide a level of additional acceptance and credibility for local 
implementation. 
B. Link disaster relief to comprehensive mitigation planning. Larger shares of disaster 
relief should be made available only to States, tribes, and local governments that have 
comprehensive plans for multi-risk reduction and sound hazard management programs. 
4. Develop incentives to encourage States and communities to foster sustainable development 
and to accept responsibility for their land use decisions. 
The Federal Government has assumed too much of the total responsibility for the flooding 
problem. Federal policies should be adjusted to foster much greater sharing of responsibility 
with State and local governments and individuals. Built-in subsidies and cross-subsidies in 
the NFIP have sent the wrong economic signals, have failed to discourage high-risk 
development, and have placed a financial burden on the Program. 
Disaster assistance has come to be an expectation disconnected from either a landowner’s 
responsibility to avoid undue risks or governmental authority to use land use regulations to 
prevent harm to the community and the environment. Unless bold, albeit unpopular, policy 
decisions are implemented, there will be no incentives for States and communities to take 
responsibility for their land use decisions and flood risks. 
A. Disaster relief cost-share adjustments may be the most effective mechanism to encourage 
communities to adopt hazard mitigation plans, foster sustainable development, and accept
Floodplain Management Forum 8 
responsibility for their actions. A sliding cost-share policy would encourage and reward 
good State and local floodplain management programs. The non-Federal share of 
disaster assistance costs should be reduced in communities where State and local efforts 
are mitigating natural hazards, including the flood hazard. 
B. For individuals, Federal financial assistance for flood losses should be based on the 
individual’s demonstrated willingness to mitigate risk. Flood insurance is the best means 
of accomplishing this. Federal monetary assistance for individuals living in identified 
flood hazard areas should be based on whether they had a flood insurance policy before 
the disaster. The total amount of assistance received by an individual should be reduced 
(or a portion of it converted to loans) to reflect the amount of damage that would have 
been covered by a flood insurance policy. 
C. Mitigation grants should be made available to policyholders who take steps to mitigate 
their flood risks. 
D. Agricultural losses constitute more than half of the flood damage paid for by taxpayers. 
Agricultural properties subject to repeated flooding should be denied subsidized 
insurance and flood disaster payments if their owners refuse offers to purchase permanent 
easements. 
E. Public assistance should be withheld from the damaged floodplain areas of communities 
not enrolled in the NFIP. 
F. Mapping costs incurred by local communities could be “banked” as a cost-share payment 
on future disaster assistance. 
G. Land use incentives such as density tradeoff should be promoted. 
5. Develop more effective methods to communicate risk to citizens and communities so that 
risk information is accurate, easy to understand, meaningful, and accessible. 
It is widely agreed that citizens and local officials are unaware of the flood hazard risks in 
their communities. Confusing terminology, inaccurate data, and complicated risk 
information are cited as some of the reasons. Increased awareness of the flood hazards and 
risks may increase public support for improved floodplain management and lead to an 
increase in the number of flood insurance policies. 
A. Use terminology such as “1-percent chance flood” or “high-risk flood” area instead of 
the confusing terminology “100-year floodplain.” 
B. Display flood hazard and risk information on the Internet.
Floodplain Management Forum 9 
C. Reinforce the importance of public safety issues to communities and citizens. 
Floodplain management is not just a land use and development issue; it is also a public 
health and safety issue. 
6. Better educate communities on the benefits of sustainable development, the natural and 
beneficial functions of floodplains, and the ramifications of unwise land use decisions. 
A. Improve the marketing of success stories. Many States and communities across the 
country are implementing innovative initiatives that are successfully reducing flood risks 
and protecting floodplains. We must do a better job of promoting our successes and 
marketing a message of sustainability, livability, and the benefits of floodplain 
management. 
B. Educate communities to exceed minimum NFIP requirements. Although the NFIP has 
done an excellent job of providing minimum requirements for development in 
floodplains, unfortunately these general standards fall short of what is needed for the 
management of floodplains. FEMA should initiate a program to educate communities 
on the limitations of minimum NFIP requirements and encourage States and 
communities to develop policies and standards that would reduce or eliminate flood 
impacts caused by floodplain development. 
C. Better educate citizens and communities on the link between floodplain management 
and the economic vitality and environmental quality of a community. 
D. Educate government officials, businesses, legislators, and individual citizens about their 
responsibility for their land use decisions. These groups must be more accountable for 
their actions, begin to assume their fair share of the risk, and not rely solely on the 
Federal Government to bail them out following a disaster. 
E. Public involvement in floodplain management must go beyond the education of public 
officials and citizenry to include meaningful public involvement during the 
decisionmaking process so that there is local buy-in for the adopted policies. 
F. Provide outreach and education to citizens and officials in the post-disaster environment 
on the natural and beneficial functions of floodplains. 
G. Develop partnerships to provide educational programs in schools. An effective way to 
educate parents is through their children. 
7. Consider modifying the NFIP requirements to prohibit or at least discourage the 
placement of fill in floodplains. 
The placement of fill in the floodplain destroys valuable riparian areas and reallocates flood 
storage from the fill site to other locations in the floodplain, thereby transferring the risk of 
flooding to other parties without compensation. Current NFIP regulations allow the 
placement of fill outside of the regulatory floodway until a 1-foot increase in the BFE is
Floodplain Management Forum 10 
reached. NFIP regulations also provide incentives to place fill in the floodplain. Through 
the issuance of a Letter of Map Revision Based on Fill (LOMR-F), a property can be 
removed from the floodplain and, thus, not be required to have flood insurance. 
A. Implement a no-rise floodway with no impact on water surface and velocity so that only 
those areas of insignificant hydraulic conveyance could be filled. 
B. FEMA should stop or severely limit the issuance of LOMR-Fs. 
8. Consider incorporating components of the Community Rating System (CRS) into the 
NFIP regulations. 
A. The CRS has been very successful in providing incentives for communities to exceed 
minimum NFIP requirements. The CRS identifies the best floodplain management 
practices and provides a strong basis for improving general NFIP standards. FEMA 
should consider identifying certain CRS activities and phasing them in as additional 
standards and requirements for community participation in the NFIP. 
9. Consider modifying NFIP requirements so that 1 to 3 feet of freeboard above the base 
flood elevation is required for all new construction in special flood hazard areas. 
A. Requiring freeboard would acknowledge and mitigate uncertainties in mapping, account 
for the 1-foot increase in floodway designations, allow for the wakes of rescue boats, 
account for increased runoff caused by future development, and provide a margin of 
safety for wind-induced wave action on wide flooded areas. 
10. Enhance the capability of State and local floodplain management programs. 
Local and State actions are critical to the protection and restoration of our Nation’s 
floodplains and to the development of sustainable communities. The roles, responsibilities, 
and capabilities of the public, various levels of government, and the private sector should 
be clarified and strengthened. 
A. Continue funding Project Impact, which has increased local capability to create 
partnerships and implement activities that protect environmental resources and reduce 
risk. 
B. Create and encourage community partnerships. Increase funding and technical 
assistance for community-based partnerships to develop comprehensive watershedbased 
solutions that reduce flood damages and protect and restore the natural and 
beneficial functions of floodplains. 
C. Provide the necessary technical expertise and tools to assist communities to better 
incorporate floodplain protection and restoration and sustainability concepts into land 
use and development decisions.
Floodplain Management Forum 11 
D. Develop strategies to bolster State floodplain management programs. There is a wide 
disparity among State floodplain management programs. Some States establish 
floodplain regulations through local governments and provide technical assistance and 
oversight, whereas others lack any type of floodplain management program. 
E. The “managing State” concept initiated by FEMA should be used as an incentive for 
State involvement in and commitment to mitigation and should be expanded to other 
programs beyond the Hazard Mitigation Grant Program (HMGP). 
11. Develop methods to improve flood hazard identificat ion and regulatory standards to meet 
the changing needs of communities. 
A. Develop coastal A-zone standards. Tremendous losses have occurred in properties 
located in in coastal area A zones. Since flood conditions in coastal A zones closely 
resemble flood conditions in V zones, the mapping and regulatory requirements should 
reflect this similarity. 
B. Accurately depict failure zones of dams, levees, and floodwalls on the flood hazard 
maps. 
C. Map future-conditions hydrology and other applicable hazards (especially erosion). 
D. Remap areas following disasters. 
E. With the advent of the Map Modernization Program (MMP) and Cooperating 
Technical Communities (CTCs), communities and States are performing flood hazard 
identification studies. FEMA must continue to be committed to these programs and 
understand and meet the needs of local communities. 
F. Strong support for FEMA’s MMP and a vigorous effort to fund the Program should 
continue. 
12. Develop methods to improve flood insurance and eliminate subsidies. 
A. Expand the flood insurance mandatory purchase requirement to areas outside of the 
special flood hazard area and areas behind dams, levees, and floodwalls. 
B. FIA should move toward requiring that a building permit be in place prior to paying 
claims. Currently, there are situations where permits are not being obtained, making it 
difficult to enforce substantial damage criteria, thus ensuring another claim. 
C. Implement a coastal erosion surcharge on flood insurance policies in areas where the 
erosion hazard can be accurately identified and mapped. 
D. Owners of secondary homes should be required to pay actuarial rates.
Floodplain Management Forum 12 
E. Begin to phase out pre-FIRM subsidies (especially on nonprimary residences). 
F. Provide greater incentives for insurance agents to promote flood insurance. 
G. “Redline” floodways and velocity zones—no flood insurance to new and rebuilt 
structures in these areas. 
H. Flood insurance coverage must perform like homeowner coverage. 
· Although the insurance industry has eliminated coinsurance penalties by 
insuring only to value (i.e., 100 percent of replacement cost), the NFIP’s 
insurance contract still contains a penalty for insuring for less than 80 percent 
of replacement cost. Unless the NFIP changes, fewer premium dollars will 
flow into the Flood Insurance Fund and more taxpayer dollars will flow from 
disaster assistance. 
· Coverage should include additional living expenses. Flood victims should not 
continue to look to Federal disaster assistance for temporary housing needs. 
I. Provide incentives, such as rating discounts and credits, for individual property owners 
who employ flood mitigation techniques.
Floodplain Management Forum 13 
Section Three Floodplain Management Forum Minutes 
Opening Remarks 
James L. Witt, Director, Federal Emergency Management Agency 
Mr. Witt welcomed attendees, presented the charge for the Forum, and expressed his hopes that 
invitees would focus on the future of floodplains. The world seems to be experiencing many 
global climate changes that cause levees to be breached and 14-inch rainfalls in 1 hour; the 
National Flood Insurance Program (NFIP) must meet these changing conditions. 
There are concerns about groundwater contamination, problems with the supply and quality of 
drinking water, and other safety issues related to development in floodplains and behind levees. 
The challenge and public responsibility facing us is to address changing weather trends, safety of 
life and property, and land use issues while preserving the environment for future generations. 
One of the responsibilities of the NFIP is to provide local officials with the education, 
information, and enforcement recommendations and documentation for them to make the policy 
decisions necessary to prevent the destruction of homes, businesses, and public infrastructure. 
The discussion was opened for participants to make suggestions directly to Director Witt on 
methods FEMA could use to improve the NFIP. He specifically requested feedback on: 
· Should floodplains be developed? If so, how? 
· Is the BFE at the 100-year floodplain an adequate measure of risk? 
· Should 1-foot freeboard be required? 
Michael Buchert, City of Tulsa, Oklahoma, recommended the following: 
· Promote floodplain designation based on full urbanization. 
· Preserve natural floodplain storage; where areas are filled, compensatory storage should be 
developed. 
· Establish zero-foot rise off each property, upstream or downstream, with 1-foot freeboard 
and no detention. 
· In Tulsa, mapping is done for drainage areas of up to 40 acres. 
Mr. Witt responded that the NFIP regulations do not provide an adequate level of protection. 
The NFIP regulations do not require freeboard above BFE, nor do the regulations require flood 
insurance behind levees.
Floodplain Management Forum 14 
Michael Ellegood, Flood Control District of Maricopa County, Arizona, suggested the 
following: 
· There should be floodplain insurance for everyone who has a mortgage; nationally, 35 
percent of all claims are made by people who do not live in a designated floodplain. 
· Hazards should be determined not just on the basis of elevation but also on geomorphology 
and erosion of watercourses. 
Larry Larson, Association of State Floodplain Managers, suggested modifications to the 
previous recommendations: 
· Examine all recommendations and program policies and make development decisions on the 
basis of “no adverse impact” on the floodplain; this concept takes into consideration future 
conditions. 
· Encourage and provide incentives for communities to develop comprehensive community 
plans so more communities can accomplish what Tulsa has done. 
Richard Krimm, Federal Emergency Management Agency, retired, recommended that 
· Insurance companies should redline new or rebuilt structures in velocity zones and 
floodways. 
· FEMA should promote setbacks in high-erosion coastal areas. 
Mr. Witt responded that a recent study showed that 64 percent of people had no idea how to 
prevent flooding disasters. In the 1990s, 2.5 million Americans moved into the southern and 
southeastern United States. This means that many people are moving into high-risk flood and 
hurricane-risk areas and are unaware of the risks and have no knowledge of prevention. 
JoAnn Howard, Federal Emergency Management Agency, added that she believes the national 
policy needs to move from a loss-prevention focus to beneficial use of the floodplain. 
Brett Hulsey, Sierra Club, Midwest Office, pointed out that many FIRMs are based on 50-yearold 
data. In repetitive-loss situations, updating FIRMs should be a priority and part of the 
disaster assistance package. He also expressed appreciation for FEMA’s leadership on the U.S. 
Army Corps of Engineers (USACE) replacement for Nationwide Permit 26. 
Mr. Witt responded that in the FY 2001 budget, FEMA has requested, and the House has 
approved, $30 million to revise FIRMs after a disaster. 
Jon Kusler, Association of State Wetland Managers, expressed his support for Mr. Larson’s 
position of a no-adverse-impact policy.
Floodplain Management Forum 15 
Mr. Witt indicated that he also believes there should be no adverse impact on property or the 
natural resources of the area. 
Gilbert F. White, University of Colorado at Boulder, asked Mr. Witt about FEMA’s involvement 
with other Federal agencies on development issues as they relate to floodplain management. 
Mr. Witt responded that the Environmental Protection Agency (EPA) and USACE are both 
represented here today and have met together many times on several related issues. 
Frank H. Thomas, Mitigation Consultant, expressed concern that the use of Letters of Map 
Revision (LOMRs), which transfer risk to other parties without compensation, degrades the 
value of the maps and the mapping program. He suggested that LOMRs be used only for 
correcting technical errors in the map data. 
Doug Plasencia, Kimley-Horn and Associates, stated his support for the no-adverse-impact 
position and suggested the importance of devolvement of responsibilities to the local level in the 
long term. This shift should start in the short term with more education to communities. The 
most important message should be that Federal regulations are not intended to be the 
recommended standard but rather the minimum threshold to be able to buy federally subsidized 
flood insurance. To think of the minimum regulations as standards leaves the governing 
authorities open to liabilities. 
Tim Searchinger, Environmental Defense, expressed support for Dr. White’s concern about 
Federal integration and cooperation. He recommended coordinated priorities for a national flood 
management program that reduce flooding damages and enhance the environment. A second 
area of concern is the crop insurance program, where those who are the most reckless receive the 
most subsidy. 
Sue Cameron, Tillamook County, Oregon, thanked Mr. Witt for assistance to the local 
communities in developing and enforcing local ordinances. She listed some recent 
accomplishments, including a 3 foot freeboard requirement and a repetitive loss provision. 
Mr. Witt shared some innovations used by Project Impact in Tillamook County, including 
elevating homes and lowering a roadbed for use as a floodway. 
John R. Sheaffer, Sheaffer International, L.L.C., stated his support for Mr. Witt’s sustainability 
objectives. He stressed that the entire water basin needs to be studied to further understand and 
manage floodplain issues. He said he supported a policy that private properties and public 
facilities should be treated equally in responsibility for this management. He further explained 
that, done correctly, urbanization can be used to decrease runoff. 
Ed Copeland, Region II Planning and Development Council (representing the National 
Association of Developmental Organizations), requested more funding for ongoing educational 
programs in responsible floodplain management techniques for local leaders and politicians. 
Changes in planning, ordinances, and financial leverage for mitigation projects can only happen 
through education.
Floodplain Management Forum 16 
Mr. Witt agreed and gave an example of how Project Impact in Vermont has encouraged 
communitywide planning. 
David R. Conrad, National Wildlife Federation, echoed several points made earlier: 
· The public education process is working and needs to be bolstered. The public eye has been 
opened to floodplain management principles, and there is recognition of the natural and 
beneficial functions of the floodplain. 
· NFIP standards need to be modernized; in particular, the components of the CRS need to 
move into standard practice. 
· He supports zero-rise or low-impact floodway standards. 
Mr. Witt mentioned several examples in which the press showcased floodplain management and 
mitigation success stories. He also shared that soon the USACE will become a Project Impact 
partner. 
Phil Oshida, Environmental Protection Agency, said he was in favor of FEMA’s efforts to 
support local prevention planning and increased funding to Project Impact communities. He also 
suggested that more incentives and rewards be provided for local communities for flood 
prevention planning and mitigation activities. 
Mr. Witt responded that it is very important to involve Federal partners, including EPA, USACE, 
the U.S. Department of Housing and Urban Development (HUD), and the U.S. Department of 
Transportation (DOT), in floodplain management, environmental protection, and Project Impact. 
Perhaps in the future, Congress could fund a Community Development Block Grant program for 
high-risk communities. 
Kenneth Ford, National Association of Homebuilders (NAHB), thanked Mr. Witt for the 
collaboration between FEMA and NAHB during the previous years, in postdisaster as well as 
predisaster mitigation, through the development of the model building codes. He did suggest, 
however, that there are still gaps in the NFIP regulations, such as crawl-space construction and 
the frustrating timelag in promulgating new or revised regulations for new methods of 
construction. 
M. Rita Hollada, Flood Insurance Producers National Committee, opined that realtors 
undermine the principles of the program by promoting development in coastal barrier zones as 
well as widespread use of LOMRs and Letters of Map Amendment (LOMAs). She urged 
lenders to start adhering to redlining on coastal barrier zones. 
Christopher P. Jones, American Society of Civil Engineers, encouraged the practice of treating 
coastal A zones more like V zones and less like riverine A zones.
Floodplain Management Forum 17 
Thomas H. Yorke, United States Geological Survey, reinforced the need for more public 
education on flood hazards. The Internet is a wonderful new technology for demonstrating flood 
zones and modeling possible scenarios. 
Mr. Witt expressed his support for the use of Internet tools. He also indicated that FEMA is 
considering shifting the responsibility for mapping and remapping to local authorities. The maps 
would then be certified by FEMA. He thanked all for coming to this Forum and for their input to 
this process. 
Statements From Participants 
JoAnn Howard, Federal Insurance Administrator, Federal Emergency Management Agency 
At the dawn of the 20th century the solutions to flooding were mostly structural; floods were 
managed by constructing dams. However, this approach, alone, pits protection of people against 
protection of the environment. This country now faces a shift in focus from loss-prevention 
activities to those that incorporate the beneficial uses of the floodplain, the renewal of land, and 
the stewardship of resources. 
A holistic view of floodplain management preserves open spaces, provokes effective zoning and 
planning, and makes neighborhoods more livable. By creating an incentive to reduce flood 
losses, the NFIP has woven disaster resistance into community planning decisions. The Program 
drives community standards and can be the incentive for a new approach to floodplain 
management. 
A new holistic approach is needed not only because the number and severity of catastrophic 
weather events is climbing but also because some people are asking whether the insurance safety 
net promotes the building of structures that are in harm’s way. FEMA is about to undertake a 
comprehensive evaluation of this program and its impact on floodplain management in the 
United States. Over the next 2 to 5 years, FEMA will examine six areas: 
1. How does the NFIP affect occupancy and use of floodplains? 
2. What are the economic, environmental, and social costs and consequences of flooding? 
3. How effectively do insurance rating and indemnity functions operate? 
4. How has the NFIP influenced local decisions on floodplain management? 
5. How effective are hazard identification and risk assessment systems, including the accuracy 
of flood maps and other risk information? 
6. How effectively does the NFIP communicate with the public? 
Ms. Howard indicated that she believes effective floodplain management solutions lie in 
marrying the desire of the public to access and live near water with the reality that degrading the
Floodplain Management Forum 18 
environment with uncontrolled development costs money, hurts people, and increases the 
incidence of destructive weather events. Floodplain management must be a partnership of 
government at all levels. “Washington” must lead, but the most innovative ideas are often 
generated at the local level. 
Michael J. Armstrong, Associate Director for Mitigation, Federal Emergency Management 
Agency 
Mr. Armstrong thanked those who came to this meeting to provide valuable input and 
encouragement, as they have many times in the past. The views and suggestions presented will 
be used not only by this administration but also by permanent FEMA staff members, who will 
continue the efforts into the future. He thanked David Holst of FEMA for taking the lead on the 
development of this Forum and the background paper. 
Mr. Armstrong stated that his greatest frustration has been the failure of the Federal Government 
to orchestrate a common goal and that the Federal Government should be better at coordinating, 
sharing information, creating a unified sense of urgency, and centralizing efforts to avoid 
duplication. He recommended Rising Tide: The Great Mississippi Flood of 1927 and How It 
Changed America, by John M. Barry, and Isaac’s Storm: A Man, a Time, and the Deadliest 
Hurricane in History, by Erik Larson, as inspirational examples of how a Government official 
can make a difference in the Nation’s policies. 
Mr. Armstrong stressed the importance of creating tools and incentives to encourage local and 
State land use laws that promote beneficial uses of floodplains. It is important to market 
livability and smart growth concepts. Floodplain management policy must be integrated with 
economic development, environmental protection, historical preservation, energy conservation, 
and public health and safety; sound floodplain management practices can be economically 
profitable. He challenged attendees to address the effectiveness of the following standards: 100- 
year versus 500-year flood elevations, freeboard, coastal erosion, alluvial fans, coastal flooding, 
and high-velocity flooding. He requested feedback about minimum standards that do not work at 
the local level, instilling a sense of ownership of the NFIP in local communities, promoting 
integration with other planning activities, marketing best practices and economic benefits, 
promoting partnerships, and developing maps that accurately reflect areas at risk and multiple 
hazards. He stressed that poor floodplain management disproportionately affects the poor; how 
can diversity and disenfranchisement be addressed? 
Michael Moye, President, Bank of America Insurance Services and the National Lenders’ 
Insurance Council (representing regulated lenders) 
Mr. Moye reiterated that most people will not buy insurance unless it is required by mandate. 
Flood insurance is for a low-probability, high-severity event, whereas fire is the opposite. He 
recommended that the program: 
· Expand the Mandatory Purchase Requirement beyond the A and V zones.
Floodplain Management Forum 19 
· Strengthen the standards for LOMAs; eliminate grandfathering; consider eliminating 
insurance subsidies to pre-FIRM structures; and require insurance for replacement cost, not 
loan balance. 
· Promote more State and local responsibility and accountability. 
W. Craig Fugate, Bureau Chief of Preparedness and Response, Department of Community 
Affairs, Florida Division of Emergency Management 
Mr. Fugate stated that we all need to do a better job of communicating risk. Most citizens are 
uninformed. The terms “100-year storm” or “500-year flood” do not adequately convey either 
the severity or potential of the hazard to most citizens. Education is needed to decrease public 
demand for floodplain development. Local authorities cannot regulate people out of hazardous 
areas until demand from the public, developers, and realtors subsides. There should be a special 
“extreme high-hazard” insurance rate for those people who continue to build or rebuild in areas 
that experience repetitive damage. 
Michael Davis, Deputy Assistant Secretary of the Army Civil Works, U.S. Army Corps of 
Engineers 
After thanking the organizers of this Forum and FEMA for their leadership in promoting good 
floodplain management, Mr. Davis reiterated the Corps’ commitment to good floodplain 
management policies. He listed some of the progress that has been achieved: 
· The Water Resources Act of 1999 was signed and contained “Challenge 21,” which provides 
money for nonstructural flood-reduction projects and ecosystem restoration in the floodplain. 
· FEMA and the Corps recently signed a Memorandum of Agreement (MOA) to bring together 
FEMA’s HMGP and the Corps’ Flood Damage Reduction Program. 
· There are new policy regulations in the Clean Water Act Regulatory Program—prohibitions 
and substantial restrictions in nationwide permits that replace Nationwide Permit 26. 
· The proposed Water Resources Development Act of 2000 would provide for the restoration 
of the Everglades, lower the non-Federal cost-share for structural flood protection to 
50 percent, and keep nonstructural protection at 65 percent to create incentives for 
nonstructural alternatives. 
· There is also proposed legislation requiring local communities to have better floodplain 
management plans to be eligible for Army Civil Works flood-reduction projects. 
· The Corps supports the effort to revise Executive Order 11988 on floodplain management.
Floodplain Management Forum 20 
Wendy Lathrop, Technical Mapping Advisory Council 
The Council is in the fifth and last year of its existence and each year has submitted to Mr. Witt 
an annual report with recommendations on mapping. This year the Council is considering the 
following issues: 
· The accuracy of flood data that are available to the public, including location of the 
floodplain as shown on the maps; the depiction of the extent of the floodplain as determined 
by hydrologic and hydraulic studies; the disparity between the historic and calculated 
severity of flooding; variability of the floodplain due to erosion, wildfires, alluvial fans, and 
ice jams; as well as the cumulative effect of development in the watershed. 
· Interpretation of unnumbered or approximate A zones can cause inconsistencies in land use 
policies and in mapping. 
· Unstudied areas that are at risk but have not been studied. 
· The cumulative effect on the watershed from the issuance of LOMAs. 
· Public involvement needs to extend beyond education to empowerment in the 
decisionmaking process so that there is buy-in and a real understanding of how floodplain 
management decisions will affect quality of life. 
· Opportunities for ongoing input to FEMA from the Council and occasions such as this 
Forum. 
Brett Hulsey, Director, Protect Our Families From Floods Project, Sierra Club Midwest 
Office 
Mr. Hulsey emphasized the following points: 
· FEMA should update all flood maps following a disaster. 
· We should protect floodplains, wetlands, and coastal areas from sprawl development through 
protection, regulation, and purchase. FEMA, State emergency management agencies, and 
local governments moved more than 17,000 homes and businesses out of the floodplains 
between 1988 to 1998 at a cost of $700 million. This money could have purchased 
easements on 700,000 acres of wetlands. 
· FEMA and State floodplain programs should review all wetland destruction permits in highflood 
counties. 
· Support the Wetlands Reserve Program, wildlife refuge expansion, and other habitat 
programs more vigorously. 
· There is a need to focus effort on top flood disaster counties.
Floodplain Management Forum 21 
· Posting should be required on real estate signs in high-flood hazard areas. 
· Make conditions for disaster assistance. 
· Flood insurance should be required behind levees. 
· At least 3 feet of freeboard should be required. 
Frank H. Thomas, Federal Emergency Management Agency, retired 
Mr. Thomas indicated that the allowance of fill in the floodplain has resulted in adverse 
consequences. 
· Fill reallocates flood storage from the fill site to other locations in the floodplain, thereby 
transferring the flood hazard and altering the risk for other floodplain properties. 
· The cumulative effect of fill degrades the accuracy of the flood maps. 
· The Flood Insurance Fund incurs a significant loss of premiums due to LOMRs. 
· Fill in the floodplain disrupts and degrades the natural and cultural resources associated with 
water supply quality and storage, wildlife habitat, etc. 
· LOMR-Fs discourage local enforcement and undermine the fundamental NFIP statutory 
responsibility to reduce flood risks and losses. 
Mr. Thomas recommended that the current policy to permit LOMR-Fs be reversed immediately. 
A policy change to terminate LOMR-Fs must assure all program constituents of fair and 
equitable treatment and be pursued using full due process of rulemaking. 
M. Rita Hollada, Chairman, Flood Insurance Producers National Committee 
Ms. Hollada pointed out that although flood damage, like fire and wind damage, is experienced 
throughout the country, few people insure against it. She indicated that the key to increasing the 
level of participation is education, simplification, and incentives. Although Project Impact, the 
CRS, and the Cover America Program have started this process, more education for homeowners 
and agents is needed. 
Ms. Hollada suggested a shift in thinking away from the concept of “flood” to the concept of 
“water.” Floods are what happen along rivers and oceans. High water can happen anywhere 
because of poor drainage or blocked storm drains and gutters. The Nation needs a Be Flood 
Alert public education campaign. 
Simplification is also key. The current program is too complex, maps are out of date and 
inaccurate, getting elevation certificates is too cumbersome, policy jargon does not parallel other 
insurance documents, rules are obscure, and payouts rarely cover the full amount of the loss.
Floodplain Management Forum 22 
They could be blended into property hazard insurance with other perils and based on sound 
actuarial rates. 
Incentives for property owners to take an active part in flood prevention could include rating 
discounts and credits for mitigation efforts. Ms. Hollada urged creative thinking in meeting 
these challenges. 
Sue Cameron, Commissioner, Tillamook County Commission, Tillamook County, Oregon 
Ms. Cameron related the Tillamook County experience. She encouraged a policy shift toward 
more holistic floodplain management that restores wetlands and tidal sloughs, improves 
floodplain capacity and connectivity, and preserves wildlife habitat. She questioned the 
reliability of FIRM data to predict flood depths and related that they now require a 
3-foot freeboard. They also have adopted a repetitive-loss provision to discourage payouts in 
repeated-flood-event areas. 
Ms. Cameron supports: 
· The current standard of 100-year (1-percent annual chance) flood, but it would be helpful to 
include 500-year floodplain data. 
· Current conditions mapping, not future conditions mapping with more robust hydrodynamic 
models and alternative data sources. 
· More complete mapping of coastal hazards, including the protective effects of foredunes, risk 
of landslides, and wave record data sources. 
· Improvement in designation of floodways, especially in tidally influenced, drowned river 
mouths. 
· Coastal mapping that includes identification of areas subject to velocity flooding and erosion 
and eliminating subsidies for development in high-risk areas. 
· Increased funding for risk-reduction activities such as elevating and acquiring structures in 
high-risk areas. 
Ms. Cameron does not support extending the mandatory purchase of insurance to areas outside 
the 100-year floodplain. 
George Bernstein, Federal Emergency Management Agency, retired 
Use the leverage you have to get managers planning.
Floodplain Management Forum 23 
Michael Ellegood, Chief Engineer and General Manager, Flood Control District of Maricopa 
County, Arizona 
Mr. Ellegood reported as the “man in the field.” He shared the following: 
· The maps are not adequate; flooding areas are not adequate measures of hazards; erosion and 
other factors need to be included in floodplain planning. 
· Nonstructural mitigation solutions should be promoted where possible. 
· Maricopa County is developing a countywide plan for all watersheds in the county. 
However, successful implementation of these countywide watershed plans requires FEMA’s 
endorsement. 
· Strong public education is a major leg of the program. 
He also expressed strong skepticism of changes in the Nationwide Permit 26 program; he needs 
to be able to get Section 404 permits in a timely fashion to maintain flood control facilities. 
Phil Oshida, Deputy Director, Wetlands Division, Environmental Protection Agency 
Mr. Oshida emphasized the following: 
· There is a need for more Federal support and incentives to do watershed planning at the 
community level to address flooding, environment, and storm water issues as well as foster 
economic growth. 
· Education and outreach should include options for structural solutions to problems and 
awareness of how actions in other parts of the watershed (e.g., upstream) affect the 
floodplain. 
· Encourage Federal, tribal, and local solutions to increase flood storage. 
· FEMA should offer comments on Section 404 permit applications relative to risk and flow 
issues. FEMA, the Corps, and EPA should develop program guidance that emphasizes the 
need to avoid and minimize impacts that significantly affect flood risks and floodplain 
hydrology. 
Christopher P. Jones, Chair, Flood Committee, American Society of Civil Engineers 
Mr. Jones stated that he believes the most difficult task for local authorities is to prohibit 
development in floodplain areas. These authorities need accurate information to accomplish this 
task. In response to the questions that were posed to the attendees prior to the meeting, he 
offered the following comments:
Floodplain Management Forum 24 
· In most cases the 100-year floodplain standard is appropriate, but sometimes it is not. An 
alternative to changing the standard is to classify structures according to their importance. 
· Coastal maps currently create an illusion of safety that does not exist. These uncertainties, 
such as erosion rates, need to be incorporated in the maps. 
· He recommended the creation of coastal A zones, which would require increased design and 
construction requirements to meet the different conditions. 
· Regarding insurance, the current data gleaned after events, which are used to establish depthdamage 
curves, are unreliable or not available. 
· Both A zones and V zones should require the same reference elevation (i.e., the lowest 
horizontal supporting member). 
Dave Canaan, Director, Mecklenburg County Storm Water Services, North Carolina 
Mr. Canaan expressed his concern about the way FEMA does business. Because of the scope of 
mapping needs and shifting priorities, FEMA will cease to be the mapping agency; that 
responsibility will shift to State and local agencies. As more of the local communities take 
control of their floodplain mapping and management, he challenged FEMA to be flexible in its 
policies and standards to meet the individual needs of each community. He stressed the 
difference between being compliant with the program and being committed to the principles. 
Albert LeQuang, Manager, Insurance Standards and Disaster Mitigation, Freddie Mac 
Mr. LeQuang related that Freddie Mac requires that all properties holding mortgages secured or 
serviced by them maintain hazard insurance against natural or humanmade perils. Freddie Mac 
requests that FEMA try to make flood insurance coverage perform like standard homeowner 
insurance coverage. For instance, the homeowner is not required to purchase more insurance 
than the amount of the loan; however, the flood insurance contract provided by the NFIP 
penalizes the homeowner for insuring for less than 80 percent of replacement cost. 
Mr. LeQuang also expressed his opinion that FEMA should bring coverage up to current 
industry standards, including additional living expenses in the case of a claim, coverage for 
cooperative buildings and condominiums, limits for multifamily rental buildings, inflation 
guards, and zone ratings. 
Ms. Howard added that the FEMA Web site (www.fema.gov) has a Call for Issues section and 
that, beginning June 15, will post results and responses. 
William Merrell, President, H. John Heinz III Center for Science, Economics, and the 
Environment 
Mr. Merrell indicated that the Heinz Center’s recent study on coastal erosion, Evaluation of 
Erosion Hazards, will be released in a few weeks and also be available on the Center’s Web site
Floodplain Management Forum 25 
(www.heinzcenter.org). The major findings of this study include that the risk from erosionrelated 
damage in the V zone has been greatly underrepresented: 
· About 25 percent of the homes in these areas will be lost over the next 60 years, with a loss 
to homeowners of about $530 million. 
· There has been a steady rise of the ocean of approximately 1.8 mm per year over the past 
100 years. 
· The NFIP pays most of these losses; rates will have to double to keep up. 
The recommendations made by this evaluation include: 
· FEMA coastal maps should include erosion hazard data. 
· The costs of projected erosion losses should be calculated in the rates. 
Jon Kusler, Executive Director, Association of State Wetland Managers 
Mr. Kusler shared his perceptions for the future: 
· If there is going to be a shift in Federal policy from managing floodplains to more than floodloss 
reduction, then it needs to be more clearly stated. 
· Historically, it has been difficult to map and regulate smaller streams, storm water, and other 
flooding areas. Perhaps the current trend toward integrated, multiobjective strategies such as 
buffers based on habitat, water quality, and erosion obviates the need for detailed flooding 
data. 
· FEMA has done a good job of cooperating with other agencies, but there may be 
opportunities to cross-train staff that are being overlooked. This collaborative strategy might 
be implemented through other agencies and legislation such as the Farm Bill and Clean 
Water Act. 
French Wetmore, President, French & Associates, Inc. 
Mr. Wetmore lauded FEMA for leadership in paying attention to the people it serves. He 
pointed out that there are two key groups of people needing information: local officials who 
need one kind of information and property owners or citizens who need a different form of 
information. A third group of people are the professionals who use educational tools to simplify 
the message and bring the information to the first two groups. He acknowledged that there are 
new tools, but averred that face-to-face contact, in the form of Community Assistance Visits 
(CAVs), is most effective in assessing knowledge and information needs.
Floodplain Management Forum 26 
He also suggested that the CRS is misunderstood and underutilized for education; so are the field 
staff of Insurance Service Officers. He supported an earlier recommendation on LOMAs and 
LOMR-Fs; wise use of the floodplain does not include making the floodplain smaller. 
He also stressed that FEMA needs to move away from the one-track mitigation emphasis on 
acquisition. FEMA would get more “return” for its funding by “buying” good floodplain 
management plans or hazard mitigation plans. 
Larry Larson, Executive Director, Association of State Floodplain Managers (ASFPM) 
Mr. Larson indicated that many of his comments were derived from the publication National 
Flood Programs in Review—2000, which was presented at the national ASFPM meeting in 
Austin in June 2000. This paper and another on the history of floodplain management will be 
available on the ASFPM Web site (www.floods.org). He indicated that the report focuses on two 
main areas: 
· Changing standards with the times. The most important policy shift is to one where 
floodplain development causes no negative impact; all other standards changes would derive 
from that premise. 
· Programs within FEMA, and elsewhere in the Federal Government, need to be examined and 
better coordinated on both the policy and staff levels. 
Michael Buchert, Assistant Public Works Director, City of Tulsa 
Mr. Buchert pointed out that Tulsa has a very active Project Impact and CRS program and 
therefore has the lowest flood insurance rate in the country. He related many of the city’s 
accomplishments but expressed concern that for all the mitigation actions the city has taken and 
standards that it has enacted and enforced, Tulsa does not get sufficient CRS point credits. He 
also pointed out that in a recent flood event, the city was denied Federal disaster status because it 
had been too successful at selling flood insurance. 
Thomas H. Yorke, Chief, Office of Surface Water, U.S. Geological Survey 
Mr. Yorke based his comments on the premise that if flood hazard identification can be 
improved, floodplain management can be more effective. The two key elements are more 
accurate flood information and tools to display the information to the public in an understandable 
way. 
The USGS streamgaging network has been the basis for much of the flood information that has 
been used in the development of FIRMs. A recent study, A New Evaluation of the USGS 
Streamgaging Network, Report to Congress 1998, indicated that the number of communities with 
accurate flood information peaked in about 1950 and has been diminishing ever since. He also 
pointed out that the available flood data are only a fraction of the historical continuum of 
flooding.
Floodplain Management Forum 27 
USGS has recently developed a plan, Streamflow Information for the Next Century, 1999, for an 
enhanced streamgaging network that will enhance the National Weather Service (NWS) flood 
forecasting program. This tool will provide more accurate methods for estimating and displaying 
flood characteristics and changes under various conditions. The aim is to make the visual 
models available over the Internet and for television feed to educate the public about potential 
hazards and projected weather impacts in their communities. 
Richard Krimm, Federal Emergency Management Agency, retired 
Mr. Krimm pointed out that the original intent of the NFIP was to make flood insurance 
available to residents of floodplains in exchange for a community’s adoption and enforcement of 
floodplain management practices. FIRMs are the basis of this program, and they have not 
changed much since their inception. FEMA, ASFPM, and the insurance industry need to make 
funding of the Map Modernization Program a fiscal priority. He suggested seven priorities for 
the program: 
1. Map for ultimate development of a community or jurisdiction. 
2. Change the program regulation on floodways to a zero rise instead of 1-foot rise. 
3. Enlarge coastal zones to include the effects of erosion and rise of the oceans. 
4. Remap the floodplain after a disaster using new technologies to prevent redevelopment of an 
area that will be subject to future disasters. 
5. Redline the floodway and velocity zones for new and rebuilt construction and do not provide 
flood insurance in these areas. 
6. Become more environmentally sensitive. 
7. Stop using Federal money for beach nourishment, which only encourages development in 
hazardous areas. 
Doug Plasencia, Associate, Kimley-Horn & Associates 
Mr. Plasencia supported Mr. Buchert’s position that the Federal Government needs to do more 
about supporting increased Federal cost-share for disaster assistance to local communities 
because of good floodplain management. He made the following suggestions for next steps to 
improve the NFIP: 
· A national standard of no-impact floodplains will return to the community the authority and 
responsibility to implement sound floodplain management as well as relieve the Federal 
Government of the responsibility to micromanage standards best dealt with at the local level. 
· Master plans will detail baseline hydraulic models and mitigation actions for each area to 
implement the floodplain management that is most appropriate for their jurisdictions.
Floodplain Management Forum 28 
· We should make use of new tools, including residual-risk flood insurance and community 
flood insurance policies. 
· State and local capabilities should be improved, and the presence of the State National Flood 
Insurance Coordinators should be increased/reinstated. 
· The Interagency Task Force on Floodplain Management should be reinvigorated to increase 
coordination. 
· Effort should be made to push for the revision of Executive Order 11988. 
Gilbert F. White, Professor of Geography, University of Colorado at Boulder 
Dr. White expressed support for the efforts of this Forum but stressed that a full national 
assessment of the NFIP is needed. He indicated that there have been several very good recent 
studies looking at specific aspects or selected communities, but there are no solid evaluative data 
to make generalized statements on the effects of the NFIP. 
He stressed that the program should not be limited to protection against flood risks but also 
should address issues contributing to sustainable development. This shift requires paying 
attention to the natural and productive uses of floodplains and other natural hazard areas, as well 
as careful attention to the whole range of natural hazards and economic and political aims. 
David R. Conrad, Water Resources Specialist, National Wildlife Federation 
Mr. Conrad stated his support for earlier statements about the policy shift to no-rise or no-impact 
floodways, nonstructural approaches, MMP improvements, future-conditions hydrology, and an 
all-hazards approach, as well as inclusion of dam and levee failure zones in Mandatory Purchase 
Requirement areas. He also encouraged sharing of the responsibility and authority with State 
and local authorities. He further recommended that FEMA: 
· Examine floodplain policies to weed out those who fail to discourage development in 
floodplain areas. 
· Set flood insurance rates on a sound actuarial basis by eliminating cross-subsidies within 
zones, phasing out pre-FIRM subsidies and grandfathering when maps are revised, 
eliminating subsidies for nonprimary residences, incorporating erosion risk factors, adjusting 
rates when conditions change, and planning for catastrophic-loss contingencies. 
· Require freeboard for new construction. 
· Continue education and encourage actions to protect the natural and beneficial functions of 
floodplains.
Floodplain Management Forum 29 
· Take steps to update Executive Order 11988. 
Kenneth Ford, Manager for Civil Engineering, National Association of Homebuilders 
Mr. Ford supported the concept of smart growth. To the NAHB, that concept means balancing 
the demand for housing with affordability, sustainability, and efficient land-use. He also stated 
his support for: 
· Shifting more control over designating local floodplains to local communities. 
· NFIP model building codes. 
· Updating maps. 
· Increasing flood resistance in existing and grandfathered buildings. 
· Clarifying standards for crawl space. 
· Continuing the FEMA and NAHB MOA that provides for education of members. 
Jerry Uhlmann, Director, Missouri Emergency Management Agency 
Mr. Uhlmann identified the following problem areas: 
· Mapping gaps and inaccuracies. 
· Shortage of NFIP-trained personnel and education of local floodplain managers. 
· Developers who challenge and circumvent the validity of zones. 
· Need to adopt actuarial rates on repeated claims and pre-FIRM structures. 
· Requiring all NFIP communities to have comprehensive mitigation plans. 
· Small Business Association (SBA) assistance loans that are not available to residents in 
nonparticipating communities, although public assistance is. 
· No sanctions for nonparticipating communities, only for individual citizens in those 
communities; need for flood assistance that is based on whether the homeowner has flood 
insurance in place and has demonstrated mitigation actions. 
· The Community Assistance Program, which needs to be revisited because it is replacing 
State capabilities.
Floodplain Management Forum 30 
· Reinstating CAVs to identify problem areas and make recommendations on actions that can 
be taken. 
· Need for the insurance industry to promote purchase of flood insurance: Only 10 percent of 
the people who should buy noncoastal flood insurance do so; many policies not renewed at 
end of term. 
John R. Sheaffer, Chairman, Sheaffer International, L.L.C. 
Mr. Sheaffer presented the following points: 
· Rainfall occurs on all land in a watershed. The people with high ground and runoff get a 
“free dump” of their share of the water to those on the floodplain. Everyone, including 
governments, should pay for flooding (or water storage) on the floodplain. 
· Floodplain management costs (cost of flood disasters as well as corrective measures) should 
be shared by all who benefit from it. 
· The rest of the floodplain should be incorporated in sustainable benefits. 
· Repetitive loss should apply to public facilities (infrastructure) as well as to homeowners. 
Ed Copeland, Region II Planning and Development Council 
Mr. Copeland explained that NADO members, known variously as councils of government, 
economic development districts, planning and development districts, or regional councils, 
provide professional and technical assistance to more than 1,800 counties and 15,000 cities and 
small towns. They are directed by elected officials from counties and communities. Most of 
these members, including all 55 counties and 98 percent of the communities in West Virginia, 
are participating members in the NFIP. 
Local officials are key to compliance and enforcement of the NFIP. He urged FEMA to work 
with these organizations. They are proactive, have existing working relationships with local 
officials, can leverage funding resources, and provide technical assistance. These communities 
want to develop geographical information system (GIS) mapping products in their communities 
by leveraging funding. The regional councils are an excellent vehicle to empower the local 
communities. 
James Sadler, Vice President, National Con-Serv, Inc. (NCSI) 
Mr. Sadler explained that NCSI is the NFIP servicing agent managing the direct insurance 
program for the FIA. He supported changes to the 100-year floodplain standard. He indicated 
that the mapping processes are antiquated and underfunded. 
Insurance is purchased because homeowners are required to do so or because they recognize the 
risks of not doing so; insurance transfers the risk. Purchase of hazard insurance is required and
Floodplain Management Forum 31 
has become institutionalized by mortgage lenders. However, the purchase of flood insurance has 
not become institutionalized. Expanding the Mandatory Purchase Requirement to all zones 
within a participating community would make the decision easier and begin to institutionalize 
the process. He added the following points: 
· Flooding hazards must be identified correctly on maps. 
· There should be premium or rate equity with actuarially adjusted rates on repetitive losses 
without intervening mitigation actions. 
Tim Searchinger, Senior Attorney, Environmental Defense 
Mr. Searchinger stressed the importance of finding incentives for local governments to 
implement good floodplain management. He suggested the following: 
· FEMA should require insurance for public facilities (buildings and infrastructure) in order to 
be eligible for disaster assistance. 
· One of the goals of mitigation projects should include environmental restoration coordinated 
with the Department of Agriculture and USACE. 
· There should be priorities developed for the use of Federal structural flood control funds. 
· There is a proposed executive directive that would require coordination in floodplain and 
wetland planning policy across Federal agencies. This directive should be supported. 
Facilitated Discussion: Mapping 
Mr. Armstrong introduced this roundtable discussion by listing some of the issues that were 
mentioned earlier today and required more discussion: 
· Toughen LOMR standards and eliminate subsidies and grandfathering. 
· 100-year and 500-year floodplain standards are meaningless; what would be meaningful? 
· Base the maps on future growth. 
· “LOMRs are a cancer”; how does one make this practical given economic realities? 
· Demonstration projects on GIS for mapping; are studies the real issue? 
· FEMA letter of endorsement as a counterpoint to taking maps out of context. 
· Classifying structures according to their importance. 
· Coastal A zones.
Floodplain Management Forum 32 
· Moving from mapping to meeting community needs. 
· Utilizing buffers to obviate the need for specific data. 
· How to move quickly and effectively into use of new types of data (LIDAR). 
· Change regulations on floodways to zero rise, enlarge velocity zones, and acknowledge 
erosion. 
· Pre-FIRM structures problem. 
· What can the private sector provide? 
In response, Mr. Moye quoted from Paying the Price: The Status and Role of Insurance Against 
Natural Disasters in the United States: “Requests for Letters of Map Change (LOMCs) have 
steadily increased over the past five years… Because the primary purpose for requesting a 
LOMC is to excuse the owner from purchasing flood insurance, the entire LOMC process 
represents a rather short-sighted attitude toward the value of insurance as well as an underappreciation 
of the flood peril.” To support FEMA in this political battle, Mr. Moye suggested 
to other members of the Forum that the organizations that agree on certain standards or policy 
modifications should jointly make that agreement known to those on “the Hill.” Regarding 
grandfathering, he indicated that he believes that insurance companies should rate the risk of 
flooding just as they do for fire and other types of hazard insurance. 
Mr. Hulsey emphasized that the maps are old. Perhaps remapping should be required as the first 
step in the recovery or mitigation process. Even a flyover map of flooded areas could aid in 
demonstrating the risk to the public. 
Mr. Armstrong responded that FEMA has started on several related activities: 
· Creating disaster recovery maps 
· Proposing funding in the FY 2001 DRF budget for FIRMs 
· Creating a sustainability/livability technical assistance desk in the Disaster Field Office 
Lisa Holland, NFIP State Coordinator, South Carolina Department of Natural Resources, 
queried whether as many people would request waivers to purchase flood insurance through 
LOMAs if they were also waiving the right to disaster assistance. Federal agencies need to work 
together to develop incentives for States and communities to assume ownership and 
responsibility for flooding hazards within their States. 
Mr. Ford pointed out that there are other natural hazards such as wind, seismic activity, and ice, 
each of which requires different and maybe conflicting building codes. It is virtually impossible 
to create an affordable, risk-free building. Builders aim for reduction of risks in a cost-effective 
manner. Policymakers need to consider private-sector realities in their deliberations.
Floodplain Management Forum 33 
Mr. Plasencia addressed the issue of funding. To date, mapping has been paid for out of a 
surcharge on flood insurance. Instead, he suggested that mapping costs incurred by a local 
community could be “banked” as a cost-share payment on future disaster assistance. 
Ms. Howard challenged the attendees to respond to the proposal to have the Federal Government 
LIDAR the entire country over the next 3 years and establish an agent database of this base-map 
information. The Federal Government could reapportion the $80 million FEMA budget to the 
communities to be used for studies that would add hazards and other data to these maps. 
Mr. Larson responded that the goal of the NFIP is to identify zones and set insurance rates. A 
LIDAR map alone is not accurate enough to regulate property and rates. 
Mr. Michael Buckley, FEMA, indicated that although it might be a good place to start, the most 
expensive part of mapping is the field study. 
Mr. Armstrong added that FEMA is required to certify an unnamed product to set insurance 
rates; they are not obligated to develop that product. By providing some of the base data, FEMA 
hopes to assist and cost-share in the process of floodplain hazard/risk identification. 
Mr. Kusler indicated that not all maps require a great deal of detail unless someone is planning to 
do something in that area. He suggested that the money might be better spent by taking more 
factors into consideration in high-need areas. He further suggested that buffer zones can help 
identify the floodplain in places where expensive engineering is not necessary or feasible. 
Mr. Ellegood offered that although FIRMs are good, they could be better if they included hazard 
information such as erosion setbacks. He further advocated that everyone, not just those in flood 
zones, should have flood hazard insurance just as they have fire hazard insurance. 
In response to Ms. Howard’s proposal for LIDAR mapping, Mr. ?? indicated that he felt it would 
be a good incentive and starting point for the communities, but policy still needs to be decided on 
how the floodplain is going to be represented on the map; no one knows how to put a future 
floodplain on a map, and the Web site does not help. A mapping effort should be the starting 
point for a hazard mitigation planning effort. 
Mr. Sheaffer pointed out a conflict in the messages: On the one hand, there is a trend to map on 
full development, which would lead to higher flood levels. However, some new development, 
which is based on sustainability, might be storing its own water and not causing any increase in 
storm runoff. 
Facilitated Discussion: Insurance 
Ms. Howard started this part of the forum by reiterating some of the topics she had heard: 
· Mandatory purchase should be expanded to areas outside the 100-year floodplain. 
· Flood risk information is not clear, nor is it adequately conveyed clearly to local officials.
Floodplain Management Forum 34 
· Risk information is not easily accessible. 
· Insurance agents want simpler products, information, and access. 
· Insurers should get rate modifications that are based on repeated loss or mitigation steps. 
· Scheduling buildings in communities would eliminate the need for individual elevation 
certificates. 
· More information is needed for better decisions and changes in policy. 
· Erosion rates need to be included in setting insurance rates. 
· There is not enough participation. It needs to be easier for insurance agents to write policies. 
· There is a land use mechanism in this country through flood insurance. 
· Redline in floodways. 
· Are we moving in the right direction with flood insurance? 
Mr. Hulsey reiterated that the public needs more readily available information and education 
about flood risks. At present, it is almost an afterthought at the time of settlement. One 
possibility would be putting National Wildlife Federation’s repetitive-loss database on the 
Internet. 
Ms. Hollada reinforced the earlier suggestions that everyone should have flood insurance and 
that it should be part of an all-perils property policy funded by the insurance industry, not 
through the NFIP. She further indicated that there will probably always be a need for a disaster 
program, but more floodplain management should happen at the local level. 
Mr. Ford suggested an incentive program such as a flood mitigation, tax credit program similar 
to energy tax incentives. 
Ms. Howard added that they had considered another incentive program aimed to obtain near 100 
percent compliance for banks. 
Mr. Armstrong added insurance credits for mitigation efforts (e.g., shutters, seismic 
strengthening) similar to credits for clean driving records and smoke alarms. 
Ms. Cameron stated that educational efforts are more productive when directed to the public 
rather than to public officials and that a term other than “100-year floodplain” needs to be 
developed. 
Mr. Conrad indicated that although he understands the insurance industry’s need to be able to 
craft a policy easily, he feels that ratings themselves can convey a sense of risk.
Floodplain Management Forum 35 
Mr. Howard Leikin, Deputy Administrator, FIA, indicated that the new Heinz report might offer 
justification for modifying policy and rating schemes to incorporate erosion data in V zones. 
Mr. Wetmore indicated that the term “100-year floodplain” must be recrafted to convey a sense 
of risk to the layperson, especially in light of 100-year floods happening every few years. He 
reinforced Mr. Kusler’s idea about a holistic, conceptual approach to floodplain management 
rather than defining standards in detail. 
Mr. LeQuang stated that recently he has been involved in trying to clarify the rating of a specific 
property. He was concerned when told by FIA personnel “not to worry about it, because it will 
all be resolved at the time of claim.” He also pointed out that the NFIP is inequitable because it 
only applies to those properties with mortgages held by federally regulated lenders. He further 
suggested that, structurally within FEMA, the recovery and insurance functions should not be 
under the same umbrella. Mr. LeQuang restated the recommendation that the basic NFIP policy 
needs to be amended to perform like other homeowner coverage : contain replacement coverage, 
eliminate the need for a coinsurance penalty, provide for additional living expenses, and provide 
for an automatic inflation escalator. 
Mr. Larson spoke about clarifying risk terminology: “One-percent risk” is better than “100-year 
floodplain,” but “high” or “moderate” is more common terminology. He also addressed 
mapping accuracy: FEMA needs to map only to regulate for the flood hazard, but individual 
communities can map for many more things to help them manage their watershed. He 
recommended that FEMA give communities not only minimum standards to meet but also 
incentives for doing more. 
Mr. Searchinger stated his belief that the 100-year flood map creates a false precision that is not 
accurate for all the reasons that have been mentioned. He suggested that the rationale for 
changing the regulation might be that FEMA needs to be able to defend a regulatory “line” that 
does not in turn quantify the risk inaccurately. 
Mr. Ellegood related that in Arizona, education and outreach are one third of the program. He 
suggested several activities that they have used in public education: listing flood zones on real 
estate property settlement sheets, erecting a booth at trade shows with aerial photographs and 
interactive map overlays, placing these same tools on the Internet, enclosing flyers in water bills, 
and educating children through schools and Scouts. 
Facilitated Discussion: Floodplain Management 
Mr. Armstrong introduced this discussion by listing some of the issues that were mentioned 
earlier today and required more discussion: 
· More State and local responsibility for initiative, financial, political, legislation, and codes, 
building on Federal resources. 
· Incentives/disincentives; financial, regulatory, or punitive.
Floodplain Management Forum 36 
· Partnership opportunities with other Federal agencies and programs (e.g., USACE, Challenge 
21, WRTA, Wetlands Permit, EPA, USGS). 
· Watershed wide planning and a multiple hazards approach, including levee and dam failures, 
in floodplain management. 
· User-friendly terminology. 
· Multihazards approach (HAZUS will be adding a flood section). 
· “Change the image of flood to the image of water.” 
· HUD should be at this table and its agenda on affordable and nondiscriminatory housing 
should apply to disaster resistance as well. 
· Reasonable flood control and keeping the overarching goal of risk reduction in mind. 
· Everyone needs to take responsibility for storage of water; new development can be 
constructed where water can be stored; how do we market this or expound on good practices? 
· “Create commitment, not just compliance.” 
· Natural and beneficial uses of the floodplain and reaching other audiences. 
· Public education. 
· “Back to basics.” 
· CAVs: How do we target them to the most appropriate and productive situations? 
· Overemphasizing acquisition to the point of ignoring other opportunities for leveraging good 
floodplain management practices. 
· Not enough CRS credits for super good programs. 
· Redlining criteria ; stop beach nourishment programs. 
· Cost-share for locals; does this mean the formula needs to be reassessed? 
· Is “risk protection” the right underlying message? 
· Smart growth.
Floodplain Management Forum 37 
Mr. Davis requested feedback on the Corps’ 1996 proposed legislation that required local 
authorities in Federal flood damage reduction projects to prepare a floodplain management plan 
as a condition of the 65-percent Federal share. Should this be strengthened? 
Ms. Cameron responded that if a comprehensive plan is required, it should be integrated with 
other related comprehensive planning efforts. 
Mr. Ellegood agreed and added that it should be done locally and in accordance with a set of 
standards; it should be peer-reviewed and when approved, receive a Federal imprimatur that can 
be used with authority. He also requested the ability to augment USACE personnel to speed up 
the workload. 
Mr. Davis thanked them for their comments and acknowledged that USACE has been operating 
under funding and staffing constraints; however, he was not sure whether supplementing Federal 
staff is feasible. 
Mr. Hulsey suggested that developers be charged a fee that could be cycled back into the 
USACE program to finance local personnel. He also recommended that Challenge 21 be 
considered a watershed management issue rather than a floodplain management issue. 
Mr. Davis agreed that Challenge 21 is a watershed-based approach that crosses many Federal, 
State, and tribal agencies’ activities. The Water Resources Development Act of 1999 will allow 
the Corps to do watershed-level analysis. 
Mr. Buchert expressed concern about the Federal Government planning for the whole watershed 
and possibly circumventing local planning processes, autonomy, and financial control. 
Mr. Wetmore also expressed concern about disconnects and inconsistencies in guidelines 
regarding local planning across FEMA and other Federal agencies (e.g., USACE) programs. 
Mr. Plasencia remarked that implementing a sliding cost-share policy on disaster assistance 
would encourage/reward good State and local floodplain management. He also indicated alarm 
about some of the mapping suggestions he had heard today. He believes that the program, the 
way it is currently designed, still needs to require detailed maps. 
Dr. White asked Mr. Davis to comment on the extent to which he thinks the major Federal 
agencies, which are involved with public works, environment management, and flood mitigation, 
can work together on watershed planning and floodplain management. 
Mr. Davis responded that the Government is committed to move in that direction, but it will take 
some clear successes to speed the process up. 
Ms. Lathrop expanded on specific areas for improvement: 
· There should be consistency of terminology within regulations.
Floodplain Management Forum 38 
· CRS credits should be given for enforcing, not just having, local ordinances. 
· Floodplain management should not just be about flood insurance but also about managing 
natural resources. 
Mr. Sheaffer pointed out that economic analyses for rate establishment need to include benefits 
to the natural resources. 
Mr. Oshida supported Dr. White’s comments on watershed planning; there needs to be more 
integration among Federal agencies to do watershed-level planning and education. 
Mr. Ellegood urged caution in mixing environmental and public safety issues in the same 
program. The motivation for the policy and the mission of the regulating agency must be clear to 
all concerned. 
Mr. Hulsey countered that constituency groups also have mixed needs and that combined voices 
send a stronger message than single-issue voices. He also pointed out that important water 
management agencies were not represented at this Forum: National Resource Conservation 
Service, especially the Emergency Watershed Protection Program, and the U.S. Fish and 
Wildlife Service. 
Mr. Kusler agreed that collecting better community-based water and related risk information is 
very important and that FEMA is the leader in this field. Communities and developers need to 
be provided with incentives to do more detailed studies. 
Ms. Cameron said that integrated planning and implementation are very hard to do, but gathering 
many more stakeholders around the table ultimately leads to a better situation. It is impossible to 
manage one aspect of a watershed without affecting other aspects. She also stated that the 
reconnaissance and feasibility studies done for the Corps, which required congressional approval 
for implementation, was the most difficult and time-consuming process ever experienced. 
Wrap-Up 
Mr. Armstrong thanked everyone for coming and participating in this Forum and for having the 
courage to say what has been said. He praised the entire community in moving forward on the 
education of citizens on the messages of risk reduction, prevention and mitigation, and 
floodplain management. Mr. Witt wants to leave a forward-moving governance legacy for future 
administrations. 
Mr. Armstrong outlined some of the key themes that he had heard: 
A. Mapping 
· The 100-year floodplain standard needs to be revised. 
· Other threats, such as levee failure, should be incorporated. 
· Adjustments should be made for anticipated maximum future growth.
Floodplain Management Forum 39 
· Maps are tools to help local authorities with floodplain management. 
B. Insurance 
· Greater incentives are needed for agents to promote flood insurance. 
· The process needs to be simplified. 
· Maps may not be the answer for the insurance industry. 
· Insurance should be expanded to include public facilities (building and infrastructure 
structures). 
C. Floodplain Management 
· Give State and local governments more ownership and accountability. 
· Expand the concept of management beyond the floodplain to the watershed and water 
management. 
· There should be disincentives to develop and incentives for planning. 
· Planning should be a requirement or “ticket” to grant dollars. 
· Planning should be a holistic approach across all Federal agency boundaries. 
Mr. Armstrong also summarized actions or accomplishments he would like to see: 
· Executive orders that require Federal-level consolidation and coordination of data collection, 
planning, and environmental assessments. 
· Flood studies in 2010: What will they look like? Will they be maps or a database? What 
new technologies will be available? What will be the cost-share? 
· An all-hazards map that includes water, wind, and seismic risks. 
· Using HAZUS to objectively rank and rate communities and States on the basis of 
vulnerability and risk; these ratings in turn drive budget priorities and trigger and filter the 
awarding of Federal grants. 
· Greater integration and acceptance by the emergency management and environmental 
communities of floodplain management, mitigation, and prevention as coequals to the other 
communities. 
Mr. Armstrong reiterated his thanks and hope that this discussion helps reinforce many issues 
that have been talked about before and motivate many to support positions and actions FEMA 
may take in the future.
Floodplain Management Forum 40 
NOTE: The minutes from the Floodplain Management Forum were generated from a recording 
of the Forum. We made a concerted effort to correctly capture each participant’s statement and 
the discussion. We apologize for any misinterpretation, errors, or omissions in these minutes.
Floodplain Management Forum 41 
Section Four Floodplain Management Forum Statements 
Improving Flood-Hazard Identification 
Thomas H. Yorke 
Chief, Office of Surface Water 
U. S. Geological Survey 
The background information distributed for this Floodplain Management Forum indicates that 
the National Flood Insurance Program prevents an estimated $1 billion per year in flood damage, 
but that annual damages due to flooding continue to rise. Changing this trend will require 
improvements in how flood hazards are identified and perceived and more effective floodplain 
management at all levels of government. My comments today are directed to how we can 
improve flood-hazard identification and convey the information to the appropriate public 
officials and individual property owners so they can make informed decisions about flood 
hazards. 
The keys to flood-hazard identification are adequate, accurate and timely data about floods and 
tools for displaying statistical information in a meaningful way so the affected parties understand 
the hazard. Much of the data used for flood-hazard identification are from the streamgaging 
stations operated by the U. S. Geological Survey (USGS) in cooperation with more than 800 
Federal, State, and local government agencies. The flood data collected at the 7,000 stations in 
the current network and the 11,000 other stations that have been operated in the past represent a 
wealth of information about floods, but the data are not adequate for identifying all flood 
hazards. A 1998 report to Congress, “A new evaluation of the USGS streamgaging network,” 
determined that only about one-half of the communities in the National Flood Insurance Program 
(NFIP) had current or historical flood data available for determining base flood elevations and 
delineating the floodplain. Another deficiency is that the systematic record of floods represents a 
small part of the continuum of floods on our Nation’s streams and rivers. We have numerous 
examples of flood frequency distributions and the associated one-percent chance floods that have 
changed as more data became available. The systematic record of floods also is affected by land 
use changes. The flood regimes of our rivers changed as forests were cleared for crops and 
pastures; they changed again as farmland was replaced by urban and suburban development. 
The USGS has proposed a National Streamflow Information Program to meet the Nation’s water 
information needs for the next century. This program, if funded, will address many of the 
information needs of the NFIP; it would include more Federal funds to support streamgaging 
stations used by the National Weather Service (NWS) for flood forecasting, more timely 
assessments of flood characteristics, new tools for improving flood inundation mapping, and an 
enhanced flood information delivery system. The funding for the streamgaging program would 
provide additional data for determining the base flood discharges and flood levels for NFIP 
communities covered by the NWS forecasting program. The assessments of streamflow 
information, which are proposed at 10-year intervals, would provide more accurate methods for 
estimating flood characteristics of streams and rivers in NFIP communities that do not have
Floodplain Management Forum 42 
historical flood information. The assessments also would enhance our ability to estimate 
changes in flood characteristics caused by various land use changes. The tools for improving 
inundation mapping include better models for defining base flood levels, delineating the flood 
boundaries, and identifying areas that will be subjected to high velocities and debris 
accumulation during floods. The new models would utilize higher resolution elevation data 
derived from Lidar. Tools also would be developed to convey flood inundation information 
rapidly to the public via the Internet. A robust information delivery system would ensure that 
critical river stage and discharge data would be delivered to the National Weather Service and 
emergency managers and that real-time flood inundation maps would be delivered to affected 
communities. 
Displaying flood inundation maps on the Internet and television has great promise for educating 
the public about flood hazards. Many people that live in the floodplain are unaware of the flood 
hazard because they did not live there during the last major flood and have never seen a flood 
insurance rate map. By showing both the areas that will be inundated and the 100-year 
floodplain each time the National Weather Service issues a flood forecast, the public would be 
become more cognizant of the flood hazard. It might also be very useful to show the areas 
behind levees that would be flooded if the levees failed. People living behind a floodwall or 
levee think they are safe, but someday a flood that is bigger than the design flood will overtop 
the levee. Increased awareness of flood hazards may increase public support for better 
floodplain management. At the very least, people living in the floodplain will be more receptive 
to purchasing flood insurance. 
In summary, enhanced flood information can serve to improve risk perception and change 
behavior. It can help communities and their citizens make good decisions that will prevent loss 
of life and decrease property losses during floods. Plans for enhanced flood data and information 
delivery developed by the USGS and others, if implemented, will decrease flood losses. The 
USGS is pleased to participate in this discussion, and we look forward to working together on 
this important activity.
Floodplain Management Forum 43 
W. Dave Canaan 
Director, Mecklenburg County Storm Water Services 
First, I would like to thank you for the opportunity to participate in the Floodplain Management 
Forum. I believe this will be a valuable exercise to start a long process of turning the tide on 
how this nation views floodplain management. 
Below, I have listed the main points of my statement that I will be making to the Forum 
participants concerning flood hazard identification and floodplain management. I am choosing 
this method to clearly communicate my key points pertaining to two of the three components of 
the program. I am not as familiar with the issues concerning flood insurance, and therefore 
reserve comment. 
Flood Hazard Identification: 
· Communities should recognize floodplain maps as a community safety responsibility. The 
time has come for communities and states to stop solely relying on FEMA to provide all of 
the floodplain maps and related data. Proper floodplain mapping is a life-safety issue - 
similar to fire, ambulance and police services. Therefore, communities and states need to 
identify stable funding alternatives (storm water fees, building permit premiums, impact fees, 
etc) to develop and maintain floodplain maps. 
· FEMA should be so committed to updated maps and CTC that the agency is willing to vary 
its role. Conversely, FEMA and its technical contractors need to embrace flexibility and start 
to understand and meet the needs of the local communities. With greater reliance on 
communities and states to perform these flood hazard studies, FEMA will have to vary its 
role (sometimes coaching, sometimes technical advisory and sometimes just getting out of 
the way…). Recent experience with FEMA has shown that they (again, including the 
technical contractors) are compliant with the Map Modernization and Cooperating Technical 
Communities concepts, but they are not committed. I am disappointed with the experience of 
Charlotte-Mecklenburg trying so hard to give FEMA, and the users of the map, pertinent data 
(free-of-charge) to make informed land use decisions. Instead, we have been met with policy 
hurdles and compared to “standards” that never seem to get out of committee. 
· Local government should recognize accurate floodplain mapping as an investment. 
Charlotte-Mecklenburg has accepted the responsibility for floodplain mapping. Charlotte- 
Mecklenburg Storm Water Services (CMSWS) is in the process of re-mapping all of the 
310+ miles of regulated floodplain. The project cost (modeling only) is approximately 
$1,200,000 – 40% federal/state funding and 60% local funding. To put it in perspective, that 
is $1,000,000 less than the match Mecklenburg County has to contribute toward the purchase 
of 116 structures in the floodplain!! In essence, mapping projects are a much better deal than 
acquisition projects!! 
· Floodplain mapping is based on an actual science. I believe there has been a recent shift to 
concentrate more on the political or “business” side of floodplain management than the
Floodplain Management Forum 44 
science. With improved technology, it should be cheaper to collect, manipulate and model 
data for better decisions in the future. Items of interest that were identified in the re-mapping 
experience in Charlotte-Mecklenburg are: (1) when using future land use conditions, flood 
heights went up as much as 4.1 feet (on average) and (2) the cumulative effect of a 1 foot 
encroachment to establish floodway districts is actually a 2.3 feet increase in flood height. 
The following are issues related to the “science” of floodplain mapping: 
A. Data collection and analysis is needed. There needs to be a concerted effort to fund the 
USGS’s gaging network to operate and maintain a base-level network of rainfall and 
stream flow gages across the US. It doesn’t matter if we are protecting to a 100-year or 
500-year flood if nobody is collecting and analyzing the data to know what is a 100-year 
and 500-year flow. 
B. Mapping is a decision-making tool for future land use. Mapping should be based on 
future conditions. Insurance does not have to, but if there is an adopted land use 
document that identifies what the future has in store for the community – then we should 
feel the obligation to try to understand the extent of the floodplain under future 
conditions. As a Project Impact community, Charlotte-Mecklenburg has embraced the 
disaster-resistant principle that acting now will dramatically reduce our future threats. 
C. Our diverse communities have different floodplain management issues. We need to 
stop the “one size fits all” approach. With appropriate mapping, the community or 
regions of a state can determine the sensitivity of development in and around the 
floodplain. The community, based on good data, can engage the development 
community in discussions to determine the amount of floodplain to be developed, if any, 
in comparison to the minimum freeboard. The selection of arbitrary 
encroachment/freeboard values or people running around proclaiming “no development 
in the floodplain” can be replaced with case studies per region/state to make the 
regulations more meaningful and effective. “No development in the floodplain” is a 
meaningless statement if you first do not know where the floodplain lies!! 
Floodplain Management: 
· The development community must have some accountability. The design engineer needs to 
accept responsibility for the location and elevation of a structure in and around the 
floodplain. Flood data is probably the only site-specific data that is provided by a 
community, state or federal government. The engineer should be required to verify that it is 
still reasonable to use the flood data. If the maps are old and/or out-dated, the developer 
should bear the responsibility of determining the correct elevation and location - or locate the 
facility well above the minimum requirements of the floodplain ordinance. 
· Laws should be enforced to make sure communities identify their risks before attempting 
to mitigate them. It is my understanding that the Stafford Act requires the development and 
adoption of mitigation plans before a community can receive hazard mitigation grant funds. 
However, I am not sure that is being enforced. If it is not required in the Stafford Act,
Floodplain Management Forum 45 
FEMA should require local communities to evaluate their exposure to losses and identify 
actions that are necessary to reduce the risk of future losses. 
· Strict policy decisions are needed to make communities and individuals assume their 
responsibility. Currently, there are no disincentives to make individuals and communities 
stop ignoring their exposure to losses. The less proactive stance a community takes today, 
can result in a greater amount of federal assistance in the future. The withholding of disaster 
funds until mitigation plans have been approved would likely entice a community to address 
its exposure to flooding. Similarly, the payment of actuarial-based flood insurance premiums 
and withholding of disaster assistance from individuals would likely entice property owners 
to take responsibility for reducing their exposure to losses. Unless drastic, albeit unpopular, 
policy decisions like these are made, there will not be any incentives for states and 
communities to take responsibility for their flood exposure. 
Again, thank you for the opportunity to share my thoughts with you and the Forum participants. 
Some of the above comments may appear pointed and harsh, but I feel that they are being shared 
in an open, professional manner. I believe they will be accepted by FEMA in that same manner.
Floodplain Management Forum 46 
Christopher P. Jones, P.E. 
American Society of Civil Engineers 
I have several comments on and suggested changes to the NFIP. My primary focus is on coastal 
issues, but some of my comments and suggested changes will pertain to the program as a whole. 
Flood Hazard Identification 
· Should the mapping of floodplains based on a higher standard, such as the 500-year 
standard? 
In most cases, No. The 100-yr floodplain is an appropriate standard for much of our floodplain 
development. However, a higher standard may be appropriate for certain types of development 
(e.g., critical facilities). One way to differentiate between types of development is to classify 
them according to their importance, and to regulate the more important structures to a higher 
standard (usually by requiring freeboard and/or different foundations). This is the approach used 
in the recently completed ASCE 24-98 (Standard for Flood Resistant Design and Construction). 
I believe much of the damage to post-FIRM structures is due to regulatory minimums which 
encourage damage during the base flood event -- these can be addressed by means other than 
regulating all new construction to a higher standard. 
Finally, while I believe it is useful to map areas subject to a 500-yr flood event, this is not always 
done during Flood Insurance Studies. Regulating to the 500-yr flood will require considerable 
effort to restudy and remap many communities. 
· Should mapping be based on future conditions, accounting for urbanization and coastal 
erosion? 
I believe flood hazard mapping should delineate areas subject to coastal erosion (the regulation 
of those areas through the NFIP is a separate issue, which may be difficult to achieve). The 
identification of these erosion prone areas will provide important information to communities, 
property owners, and prospective purchasers. In short, I am in favor of disclosing known 
hazards, whether or not NFIP regulations follow. 
· Are hazards such as coastal erosion, alluvial fans, coastal flooding, high velocity flooding, 
and similar hazards adequately addressed in the hazard identification and mapping? 
With regard to coastal flood hazards, No, for two reasons: 1) coastal erosion is not yet mapped 
(see responses to questions above and below this response); and 2) Coastal High Hazard Areas 
(V zones) shown on FIRMs may not capture all the areas where buildings are at increased risk 
during coastal flood events. 
The premise behind the establishment of many V zones is that a 3-ft wave is the minimum wave 
height necessary to cause damage to a building, or that other related conditions (high velocity 
flow, scour and storm-induced erosion) will not occur in areas where wave heights are less than
Floodplain Management Forum 47 
3 feet. Recent FEMA-sponsored full-scale laboratory tests on breakaway wall sections shows 
wave heights less than 2 feet are capable of destroying walls and connections. Also, observations 
of building performance after coastal flood events frequently show damage to post-FIRM 
buildings in coastal A zones, constructed in compliance with NFIP requirements. 
Rather than defining a new boundary for the V zone, I recommend a simpler approach -- 
classifying certain A zones as Coastal A Zones (i.e., differentiating between coastal A zones and 
non-coastal [e.g., riverine] A zones). Increased design and construction requirements should be 
attached to the Coastal A Zone designation (see response to Floodplain Management question on 
coastal hazards). 
Flood conditions in coastal A zones are usually closer to conditions experienced in V zones than 
those experienced in A zones away from the coast -- our mapping and regulatory requirements 
should reflect this distinction. 
· Are there methods of identifying flood hazards other than the traditional mapping approach? 
Regarding coastal erosion, the traditional approach used by many states and communities is to 
map a future shoreline position based on a long-term, average annual erosion rate (e.g., 1 ft/yr, 
3 ft/yr, etc.) applied over a specified time period (usually 30 years to 60 years). We commonly 
report these erosion rates with the implication that future shoreline positions will follow the 
stated linear trend. This is rarely the case. Erosion rates at a given site can vary through time, 
and a single rate may not provide the information needed to properly evaluate the vulnerability 
of a given site. 
If the NFIP maps coastal erosion, I am in favor of showing an erosion hazard area that reflects 
the uncertainty in the prediction of future shoreline positions. I recommend we move away from 
the exclusive use of long-term, average erosion rates to communicate the erosion hazard at a 
particular location. Instead we should consider showing a band, rather than a line, to indicate the 
likely shoreline position at some specified time in the future, or we should consider mapping the 
most landward expected shoreline position over some defined future period. These approaches 
would take erosion rate uncertainty and non-linear shoreline change trends into account. 
Floodplain Management 
· Should freeboard be required above the base flood? 
Freeboard should be encouraged in all cases, but required for more important classes of 
buildings. 
In the case of A zone structures, the reference elevation for the lowest floor should be changed 
from the top of the floor to the bottom of the lowest horizontal supporting member. I do not 
understand the application of a top-of-floor requirement that guarantees flood damage during the 
base flood. The CRS gives communities credit for adopting the lowest horizontal supporting 
member requirement for A zones, but I believe this approach does not go far enough.
Floodplain Management Forum 48 
· Are hazards such as coastal erosion, alluvial fans, coastal flooding, high velocity flooding, 
and similar hazards adequately addressed in the regulatory requirements? 
As was stated previously, present flood hazard identification methods and floodplain 
management requirements understate the risks to development in many coastal A zones. More 
stringent elevation, foundation and other requirements should be instituted by the NFIP for these 
areas. For example, it is ludicrous to allow fill or solid walls to be used for structural support in 
Coastal A Zones -- pile or column foundations should be employed in these areas. 
The Coastal A Zone concept is already taking hold. FEMA’s recently revised Coastal 
Construction Manual provides recommendations for designers, building officials and others 
regarding appropriate design and construction practices for Coastal A Zones (see Table 6.1 of the 
Revised CCM). ASCE 7-98 (Minimum Design Loads for Buildings and Other Structures) 
requires designers to consider different load factors and load combinations for coastal A zones 
and non-coastal A zones. As communities adopt the International Codes, the ASCE 7-98 
provisions will be in place. As communities use the Revised Coastal Construction Manual, 
many Coastal A Zone recommendations will define best practices. 
· What strategies can be developed to encourage communities to adopt hazard mitigation 
plans or comprehensive plans and policies that steer development out of floodplains? 
It has been my experience that the single hardest thing for a community or state to do is to 
prohibit development in floodplain areas. We can encourage all we want, but the fact remains it 
will be difficult to prevent further development of floodplains or remove the development that 
exists there today. I believe we would be better served by the accurate identification of the most 
hazardous floodplain areas, and by modified financial incentives/disincentives (e.g., flood 
insurance premiums, deductibles and payments, disaster assistance) associated with development 
therein. 
Insurance 
· Is the current flood insurance rating model sufficient, or are there other methods to rate the 
flood risk? 
The data used to establish depth-damage curves (and flood insurance rates?) for V zones are outof-
date and should be re-examined. 
Claims data should be examined to determine different depth-damage curves and insurance rates 
for Coastal A Zones and non-coastal A zones. Data for the two areas are mixed at present, and 
the resulting depth-damage curves and insurance rates are probably biased toward non-coastal A 
zones. 
Finally, consideration should be given to the collection of more detailed and accurate flood 
claims data by adjusters, from which improved depth-damage curves and insurance rates could 
be derived. My review of a limited number of coastal flood claims data suggests the quality of 
the data is not adequate and could be improved greatly.
Floodplain Management Forum 49 
Attachment to Statement by Christopher P. Jones, P.E. 
Floodplain Management Forum, June 8, 2000 
Table 6.1 (Summary of NFIP Regulatory Requirements for V Zones, Coastal A Zones and 
A Zones, and CCM* Recommendations for Exceeding the Requirements) 
*Taken from FEMA 55, Coastal Construction Manual: Principles and Practices of Planning, 
Sitting, Designing, Constructing and Maintaining Residential Buildings in Coastal Areas, 
Federal Emergency Management Agency, Mitigation Directorate, Washington DC, 2000.
Floodplain Management Forum 50 
M. Rita Hollada, CPCU, CIC, CPIA 
Chairman, Flood Insurance Producers National Committee 
I have chosen to view the issues to be discussed today from a local rather than a national 
perspective. I speak as an insurance agent who has spent years helping the individuals of my 
community recognize and understand their exposures to loss. Water damage, like damage by 
wind and fire, is assuredly one of the risks faced regularly by the members of my community and 
all others throughout this country. And yet, so few people anticipate and insure the flood risk. 
The solution to increasing the level of protection against flood risks lies in three key points: 
education, simplification and rewards to individual property owners. 
I applaud the FEMA initiatives such as Project Impact, CRS Communities and the Cover 
America Program which have resulted in strengthening the awareness of the flood risk in 
communities throughout the country. Now it is time to get personal and educate each and every 
individual insurance agent and property owner that the danger of water damage is real for them, 
regardless of location! Water is everywhere. One of the biggest stumbling blocks to awareness 
may simply be the use of the word flood. 
The word “flood” inspires images of a swollen river, not a swollen street. Flood evokes visions 
of a violent, storm driven sea, not the hillside gushing water from a violent downpour. FEMA 
and the NFIP talk about “floodplains”, not the low-lying end of a neighborhood cul-de-sac. The 
news media discusses one hundred and five hundred year flood levels, not water levels from 
blocked storm drains and culverts. Average people like you and I sit back smugly and say “ it 
can’t happen to me” because I don’t live on the river or near the ocean. 
We need to expand the image of flood to water damage that occurs anywhere and everywhere 
from a variety of sources. Educate the average property owner through community awareness 
programs. If we can have a “neighborhood crime watch,” why not a “neighborhood flood 
watch?” The new Be Flood Alert brand of the NFIP lends itself to so many opportunities. 
Subdivisions can stencil the Be Flood Alert logo on streets and curbs near storm drains which 
could be blocked. Areas subject to flash flooding from storm runoff could be marked by a Be 
Flood Alert road sign. In fact, swimming pool shipping boxes could have Be Flood Alert 
symbols to remind homeowners to place the pool where a mishap won’t cause a local flood. 
Partner with insurance companies and agencies to take education programs into the schools. 
Certainly we have the models for this in the Hartford’s fire prevention program and 
Nationwide’s after prom initiative. Children will make parents alert to the danger of water 
damage. Educate in small, local ways and the result is flood awareness in a big way. 
The second key point is simplification. The flood insurance program as it exists today is simply 
too complex. The maps in use are outdated and bear no relationship to a modern road map. 
Streets are not named and whole subdivisions remain unidentified. Obtaining an elevation 
certificate for each specific property is a costly and time-consuming endeavor. The flood policy 
itself contains language and concepts, such as voidance and reformation that are not found in the
Floodplain Management Forum 51 
remainder of the insurance industry. Obscure rules, like the single building rule or the 51% rule 
or the substantial damage rule remain incomprehensible to most agents, lenders and consumers. 
And when all is said and done, the consumer is rarely paid the full amount of the loss. 
It is time for some creative thinking and simplification of the flood insurance mechanism. If the 
goal of this forum is to develop strategies that will increase the number of property owners who 
have some financial protection for the hazard of water damage, then lets look at possible 
alternatives to a bigger, more complex National Flood Insurance Program. 
After thirty years of the NFIP, there must be enough actuarial data for the private insurance 
sector to establish a rate for the water damage exposure. We could simplify the flood insurance 
mechanism by including the peril of water damage in every property insurance form while 
charging for it based on actuarially sound rates. The coverage would not have to be for the full 
property value, but could be for a minimal amount such as 15 or 20 thousand dollars of coverage. 
The insurance industry offers a similar, limited product through the “Sewer Backup and Sump 
Overflow” endorsements now available in the private sector. 
Since many flood claims are small in nature, covering a limited amount of water damage as any 
other peril in the basic property policy would give many consumers all the financial protection 
needed. The National Flood Insurance Program could then become an added layer for those 
properties with a catastrophic exposure. Since a first layer would be spread among the insurers 
in the private sector, this second layer could be rated based on community average elevations and 
the rate tables collapsed. Perhaps the coverage itself could follow the language and form of the 
basic property policy with regard to perils insured against, definitions and conditions. If the 
product itself could be simplified, there would be greater understanding, trust and confidence in 
the flood insurance mechanism. 
The third and last of my points is to reward those who take an active part in flood prevention and 
control. Rating discounts and credits could be offered to individual property owners who 
employ flood mitigation techniques. For example, a homeowner who constructs French drains 
or builds a containment pond might receive premium credit. Homes built on vented crawl spaces 
rather than slabs would receive a policy discount. If the insurance industry can offer discounts 
for smoke detectors and burglar alarms, why not for water damage control. 
In contrast, we can no longer afford to reward those individuals who refuse to accept personal 
responsibility and participate in efforts to prevent flood loss. We need to have the will to say no. 
My comments are in no way intended to be solutions ; they are intended to be ideas. It is time to 
get creative. The definition of insanity is doing the same thing and expecting different results. 
Let’s look for innovative and different solutions to the same old problem. If we do not educate 
every individual regarding the risk of water damage; if we do not simplify the flood insurance 
product to make it easily accessible and understandable to the individual property owner and if 
we do not reward that individual property owner’s water control efforts, then we do not have a 
hope of reaching the penetration and control of the flood risk that everyone in this room so 
desperately desires.
Floodplain Management Forum 52 
Larry Larson 
Executive Director 
Association of State Floodplain Managers 
The ASFPM is pleased FEMA is recognizing that current floodplain management standards and 
approaches in the nation are not adequate to prevent at risk development or to create sustainable 
communities. The nation has made progress over the last 50 years, and especially in the last 8 
years, in moving from only structural programs to adding non-structural approaches of 
acquisition/relocation, elevation, floodproofing and multiple objective, locally based approaches 
which consider the watershed and ecosystem. Despite this progress, flood losses continue to 
increase, as evidenced by increased disaster costs. 
We provided FEMA a copy of ASFPM’s recent report "A National Flood Policy in Review -- 
2000" which lays out a complete approach to adjusting national policy to reduce flood losses and 
create ecological integrity. However, we also developed this paper to respond to specific issues 
in the FEMA background paper in order to assist FEMA focus its effort quickly and effectively 
on "do-able" changes. 
First, it must be stated that any changes in how the NFIP can be a stronger agent in this process 
must be approached in two contexts: 
A. Addressing and modifying basic development and re-development standards of the NFIP 
to provide a safer level of protection from flooding. 
B. Addressing the role of the NFIP in the context of floodplain. The NFIP is but one part of 
floodplain management at the community level. The issue here should be to determine 
how the NFIP (and other FEMA programs) can best support comprehensive local 
floodplain management efforts, as discussed in the third paragraph of the FEMA paper. 
The FEMA paper identifies the need to develop new strategies in 4 areas: (1) better identify 
flood hazard risk, (2) provide a higher level of protection against flood risks, (3) cultivate a 
greater sense of responsibility and accountability, and (4) encourage states and communities to 
foster sustainable development. While context A above (changing NFIP standards) can be used 
to develop strategies 1 and 2, in order to effectively develop strategies 3 and 4, the broader 
context in B above, involving programs beyond the NFIP must be included. 
On the first context of modifying the NFIP standards, we suggest it be looked at from the 
position of (a) standards for new development and (b) standards for re-development and 
improvement. The current NFIP standards for both of these seem designed to protect the 
insurance fund, not to encourage the community to create sustainable development. Therefore, 
when locals follow the NFIP standards in guiding development, these minimal actions induce 
flood damages. 
We will address NFIP standards in the format suggested in the FEMA paper; flood hazard 
identification, floodplain management, and insurance.
Floodplain Management Forum 53 
Flood Hazard Identification 
100 year standard--We recognize that protection provided by the 100 year standard, as it is 
currently determined and applied, does not provide true protection to the 1% flood event. 
Properly determined and applied, we believe the 1% standard for most development and redevelopment 
is appropriate, and the 0.2% standard is appropriate for critical facilities and 
structural flood control measures. However, for the 1% standard to provide adequate protection, 
these changes are necessary: 
· A no-rise floodway with no impact on water surface and velocity should be required, so that 
only those areas of insignificant hydraulic conveyance could be filled. Allowing cumulative 
filling of the floodplain until a 1-foot increase in base flood height is achieved (the current 
standard) causes additional flood damage on properties in the floodplain, increases 
downstream flood peaks, and promotes the filling of riparian zones that would be valuable 
natural resources if left undisturbed. 
· To reduce the cost of re-mapping, minimize future damage, and improve sustainability, flood 
maps should be based on future-conditions hydrology unless ordinances require that there be 
no increase in the post-development runoff discharge compared to the pre-development 
discharge. 
· Flood hazard maps should be developed that depict all related hazards, for example, the 
failure zones of all dams, levees, and floodwalls. Not only is this identification important for 
notification and warning purposes, but also development in these zones should have added 
flood protection, and flood insurance should be mandatory, with rates based on the residual 
risk. 
· There needs to be full integration of geologic and other unique hazards into the floodplain 
mapping process, because land subsidence, landslides, and mudflows, as well as sediment 
flow, arid region flooding, closed basin lakes, ice jams and others can exacerbate flood 
hazards. 
· We must find clearer ways to communicate flood risk so that it is meaningful to citizens and 
communities, thus enabling them to take appropriate steps to reduce risk and damage. The 
confusing terminology “100-year floodplain” should be abandoned in favor of language that 
is more understandable to the layperson. The ASFPM suggests using “1% chance flood.” As 
an alternative, the broader terms “high-risk flood” could be used for the 100-year flood and 
“moderate-risk flood” when referring to the 500-year (or 0.2% chance) event. 
· Flood Hazard mapping must identify stormwater flooding areas. It is not reasonable to 
insure structures in these areas, yet not require the areas to be mapped or regulated. 
Stormwater programs must be integrated at the federal level with water quality programs of 
EPA. 
· While it is tempting to try to find quick and cheap ways to identify flood hazard areas in 
order to reduce costs and produce maps more quickly, flood hazard mapping is the basis of 
local regulation of property. Private property cannot be regulated without due notice, and the 
maps must be defensible in court as accurate. Differences of small amounts in flood
Floodplain Management Forum 54 
elevations or floodway locations can mean big money to some developers, thus providing an 
incentive for them to fight the accuracy of the maps in court. The current process, as 
outlined in the Map Modernization Plan, is designed to ensure accuracy of the maps, which 
we strongly support. 
Floodplain Management 
· Consideration should be given to modifying the National Flood Insurance Program 
requirements so that new construction has from 1 to 3 feet of freeboard above today’s 
estimated base flood elevation. This would acknowledge and mitigate uncertainties, account 
for increased runoff caused by future development, allow for the wakes of rescue boats, and 
provide a margin of safety for wind-induced wave action on wide flooded areas. 
· In unnumbered A zones, there seems to have been a misapplication of the guidance to default 
to 36 inch depth 
· For closures below BFE; there is a disconnect between 300 square foot insurance trigger and 
not size limit under 60.3 (enclosures this large encourage conversions) 
· National Standards should be developed for the design and placement of infrastructure to 
avoid damage from flooding and other hazards. Infrastructure damages are paid for under 
Public Assistance after disasters, and constitute a major portion of disaster costs taxpayers 
cover. 
· New structural measures should be built to protect not just to the 1% chance flood, but rather 
to the 0.2% chance flood, to avoid losses from catastrophic failure. 
· There is a need for a maintenance, inspection, and safety program—similar to the Federal 
Emergency Management Agency’s Dam Safety Program—to oversee flood control works in 
total. 
· Flood hazard maps should depict the failure zones of all dams, levees, and floodwalls. Not 
only is this identification important for notification and warnings, but also development in 
these zones should have added flood protection, and flood insurance should be mandatory. 
· Zoning below dams should be tied to failure zones to prevent low-hazard dams from 
becoming high-hazard dams. 
· The National Flood Insurance Program should be modified to provide an insurance policy 
benefit for coastal erosion and mudslides only where those hazards are clearly mapped and 
regulated. 
· Another approach in coastal areas would be the establishment of setback requirements for 
new construction and substantial improvements to existing construction along eroding 
shorelines. Residential structures would be allowed only if they are moveable. 
· Under the National Flood Insurance Program, the coastal zone designations and their
Floodplain Management Forum 55 
accompanying construction standards should be revisited. A Zone standards are inadequate in 
those coastal areas now defined as overwash, or AO, Zones. These areas are not V Zones, but 
they still can experience up to 3-foot breaking waves and significant flow down the backside 
of dunes and street ends. The wave action and velocity dictate different standards for coastal 
A Zones and riverine A Zones. The Federal Insurance Administration recognizes the possible 
need to differentiate, in the insurance rates, between the two types of A Zones. 
· Approvals of future coastal development should be contingent on the demonstration of 
adequate plans for and the ability to evacuate the at-risk population. 
· Periodic reviews also should be done of state and local floodplain management policies and 
programs, to identify what successes have been achieved in certain states and locales, what 
contributed to that success, and how they could be duplicated elsewhere in the nation. 
· Agricultural levees should be constructed so that they have no impact on the flood heights or 
the floodway of the 1% chance flood. 
· The Federal Emergency Management Agency should consider identifying certain 
Community Rating System activities and phasing them in as additional standards and 
requirements for community participation in the National Flood Insurance Program. 
A number of strategies could be considered to encourage communities to adopt hazard mitigation 
plans, etc., to steer unwise development from flood hazard areas and to encourage citizens to 
accept responsibility for their actions. A number of these are enumerated in our Policy Review 
paper, and focus on incentives which reward local communities who go beyond the minimum 
national standard. CRS provides some incentives to property owners, but larger incentives must 
be developed for communities, to spur local and state legislators and policy makers into taking 
actions. That usually means something that impacts them fiscally. The most appropriate 
mechanism, which should be tied directly to the NFIP, is the Disaster Relief cost-share. 
(a) For individuals, federal financial assistance for flood losses should be based upon the 
individual’s demonstrated willingness to mitigate the risk. The ASFPM believes that 
flood insurance is the best means of accomplishing this. For example, those living in 
identified flood hazard areas should not receive financial assistance if a flood insurance 
policy was not in place at the time of the flood. Additional mitigation grants should be 
made available to policyholders who take steps to mitigate their flood risk. The premiums 
on structures with repetitive losses and on those that are not primary residences should 
reflect the actual risk. 
(b) For farmers, federal incentives and programs like the Conservation Reserve Program, the 
Wetlands Reserve Program, and permanent easements are vital financial assistance in the 
development of sustainable uses for floodprone lands. Agricultural losses constitute over 
half the flood damage paid for by taxpayers—amounting to billions of dollars. The trend 
of heavy government support, such as highly subsidized crop insurance and flood disaster 
payments on floodprone lands, is neither sustainable nor reasonable, especially for 
marginal agricultural lands that flood frequently. In addition to major losses from 
flooding, farming marginal land leads to pesticides, herbicides, fertilizers, and sediment 
polluting the nation’s waters, and the resultant loss of valuable riparian ecosystems. Such
Floodplain Management Forum 56 
uses are not sustainable. Agricultural properties subject to repetitive flooding should be 
denied subsidized insurance and flood disaster payments if their owners refuse offers to 
purchase permanent easements. 
(c) For states and localities, programs for flood control structures, nonstructural flood 
measures, mitigation, and flood disaster assistance should all be based on the same, 
sliding cost-sharing formula for federal assistance. Under this concept, a minimum costshare 
would be made available to all localities but the federal share would be increased 
for communities and states that engage in disaster-resistant activities exceeding minimum 
criteria and that are implementing strong mitigation programs. After a flood disaster, 
Public Assistance under the Stafford Act should be withheld from the damaged 
floodplain areas of communities not enrolled in (or not in compliance with) the National 
Flood Insurance Program. The “managing state” concept initiated by the Federal 
Emergency Management Agency should be used as an incentive to state involvement in 
and commitment to mitigation, and be expanded to other programs beyond the Hazard 
Mitigation Grant Program. 
(d) All taxpayer-funded flood disaster relief should be contingent upon taking flood 
mitigation action. 
· The roles, responsibilities, and capabilities of the public, the various levels of government, 
and the private sector should be clarified and strengthened. Citizens, businesses, and local 
and state legislators need to better understand that the federal government will not always 
bail them out after a flood. They must bear their fair share of the risk. 
· Public Assistance should be withheld from the damaged floodplain areas of communities not 
enrolled in (or not in compliance with) the National Flood Insurance Program. Today there 
are few, if any, economic sanctions for local governments that fail to participate in the 
National Flood Insurance Program, even though their failure makes their citizens ineligible 
for Individual Assistance, federal home loans, and other services. In effect, the individual 
citizens are penalized, while the municipality continues to get bailed out. 
· Federal financial assistance for flood losses should be based upon the individual’s 
demonstrated willingness to mitigate the risk. The ASFPM believes that flood insurance is 
the best means of accomplishing this. For example, those living in identified flood hazard 
areas should not receive disaster assistance if a flood insurance policy was not in place at the 
time of the flood. Additional mitigation grants should be made available to holders of flood 
insurance policies on primary residences and commercial structures who take steps to 
mitigate their flood risk. The premiums on structures with repetitive losses and on those that 
are not primary residences should reflect the actual risk. 
· Similarly, the non-federal share of disaster assistance costs should be reduced in 
communities where state and local efforts are mitigating the flood hazard. Proposals before 
Congress have suggested penalizing communities that do not achieve a minimum standard, 
but an incentive program makes more sense both politically and from a public policy 
standpoint. 
· Federal monetary assistance for individuals should be based upon whether they had a flood 
insurance policy before the disaster, even if their property lies outside of the 1% chance
Floodplain Management Forum 57 
floodplain. The total amount of assistance received by an individual should be reduced (or a 
portion of it converted to loans) to reflect the amount of damage that could have been 
covered by a flood insurance policy. 
· The Community Assistance Program needs to be revisited because, although it has provided 
products for the Federal Emergency Management Agency, it has tended to replace state 
capabilities rather than encourage states to develop more of their own capacity. 
· Some modifications to the insurance aspects of the National Flood Insurance Program would 
enable it to better support flood loss reduction. These changes include improving the 
Increased Cost of Compliance eligibility and funding provisions so that more damaged 
structures are mitigated with assistance from individual flood insurance policies; finding 
ways to move toward actuarial rates for policies on repeatedly flooded structures; finding 
new methods to determine flood risk for insurance purposes so that information useful for 
community planning and floodplain management can be left on flood maps; and providing an 
insurance policy benefit for coastal erosion and mudslides only where those hazards are 
clearly mapped and regulated. The ASFPM believes that this can be done at a net savings to 
the National Flood Insurance Program 
· Programs such as the Federal Emergency Management Agency's Project Impact, which 
fosters the development of model “disaster-resistant” communities through public-private 
partnerships, citizen involvement, comprehensive planning, and a multi-hazard and multipurpose 
approach to mitigation, should be expanded and encouraged. 
Insurance 
· Flood insurance purchase requirements should extend beyond the 1% flood hazard area, 
which could be required when disaster or insurance claims are made. 
· The current flood insurance rating for Pre-FIRM structures does not encourage mitigation, 
since they pay the same rate regardless of depth of flooding. 
· Authorization of a provision in the NFIP for mitigation insurance that would include 
conditions to deal with repetitive loss structures. 
· Redefining “substantial improvement” under the National Flood Insurance Program so that 
improvements to a structure over time are treated cumulatively, rather than each 
improvement being considered individually. The National Flood Insurance Program should 
require communities to adopt the cumulative improvement language. 
· In cooperation with its partners, the Federal Emergency Management Agency needs to 
develop a clear position on whether “replacement cost” or “market value” should be used 
when substantial damage or improvement is evaluated. In general, the ASFPM has found that 
replacement cost is a better standard in coastal areas, while market value works better in 
riverine locales. 
· Repetitive losses could be financially neutralized by moving to actuarially based premiums 
and/or deductibles on such structures and adjusting coverage unless mitigation measures
Floodplain Management Forum 58 
(including dry and wet floodproofing) are undertaken. If cost-effective and feasible 
mitigation options are refused by a property owner, premiums for that structure should be 
increased. 
· The repetitive loss structures database needs to be cleaned up to include data to show the risk 
and reason for flooding of each structure and to verify building locations. 
· The Increased Cost of Compliance provision could be made more effective by relaxing the 
eligibility requirements so more damaged structures could receive Increased Cost of 
Compliance mitigation funds (after over two years, fewer than 150 structures have qualified 
for this mitigation help); implementing the third provision of the Increased Cost of 
Compliance law, which allows the Director of the Federal Emergency Management Agency 
to impose Increased Cost of Compliance when it is “beneficial to the National Flood 
Insurance Program Fund;” and encouraging property owners to undertake mitigation by 
increasing the amount of funding available. 
· Steps should be taken to bring the estimated 40% of new mortgages that are not federally 
regulated under the provisions of the mandatory purchase requirement. 
· Properties in dam and levee failure zones that are bought with federally backed mortgages 
should continue to be subject to the mandatory flood insurance purchase requirement, with 
rates based on the residual risk. 
· In Coastal erosion areas, one option the ASFPM favors is an erosion hazard surcharge on 
National Flood Insurance Program policies if the areas subject to erosion can be accurately 
identified and mapped. 
· Owners of secondary homes should pay flood insurance rates based on the actual risk to that 
structure, should be responsible for the structure's recovery and repair costs after a flood 
disaster, and should bear the full cost of mitigation measures for that structure. 
· The accuracy and ready availability should be ensured—preferably through a national 
database—of (1) the information on flood-damaged structures that is already collected by 
federal agencies, contractors, and others; (2) National Flood Insurance Program claims 
information, including location of the insured property, amounts of claims payments, and 
value of the property; and (3) data on repetitive loss structures, including the risk and reason 
for flooding of each structure. There are several ways to do this. For example, localities could 
be required to identify the number and risk of structures within their jurisdictions as part of a 
local mitigation plan done under the Flood Mitigation Assistance Program or the Hazard 
Mitigation Grant Program. 
With regard to the second context described at the beginning of this paper, we urge FEMA to 
ensure all FEMA programs, not just the NFIP, support wise and sustainable floodplain use. 
These would include the disaster programs like PA, IFG and all mitigation programs. In 
addition, FEMA should do everything in its power to convince the Administration, including 
OMB and CEQ, to establish senior level coordination on flood policy issues, and put them in the 
“sustainable, multiple objective” context. A policy level coordinating mechanism worked fairly
Floodplain Management Forum 59 
well after disasters in the mid-90's, but must be an ongoing mechanism. Key items to pursue 
include: 
· A National Floodplain Management Policy should be established. It should include a national 
riparian zone policy of protecting, maintaining, and restoring riverine areas in order to 
preserve them as sustainable ecosystems for future generations. Buffer zones along rivers, 
streams, and smaller waterways need to be encouraged. The Continuous Conservation 
Reserve Program could be converted to a permanent nationwide easement program for 
riparian buffers. Emphasis should be placed on maintaining the natural flood storage capacity 
within all watersheds. 
· FEMA’s has spent considerable time developing a report on the Natural and Beneficial 
Functions of Floodplains. It is most important for FEMA to complete and release the report, 
and to implement the recommendations of the report. 
· A coordinated, watershed-based, multi-objective approach for all water resource activities 
must be adopted. It should include coordination with water quality improvement efforts, the 
creation and maintenance of upland storage, and coordinated planning among upstream, 
downstream, rural, and urbanized localities within the same watershed. 
· The federal government should set an example by enforcing appropriate restrictions on 
floodplain lands it leases, and terminating those leases on schedule. In some areas of the 
nation, buildings exist on floodplain lands leased from the Corps of Engineers. These leases 
were intended only to “live out” the original landowners and then expire, and they included 
clauses specifying that neither flood insurance nor flood disaster relief would be available to 
the owners. A further condition was that the buildings were not to be converted into 
permanent homes, although most of them have been. However, because of political pressure, 
hundreds of these properties receive flood insurance claims payments and disaster relief, and 
leases are being renewed because Congress will not allow the Corps of Engineers to 
terminate them. In Illinois, these properties make up a significant proportion of the state’s 
repetitive loss properties. 
· A new Executive Order should be issued, with an expanded scope and mechanisms for 
enforcement and accountability. This would reaffirm the federal government’s commitment 
to floodplain management. 
There also needs to be a working level coordination mechanism for the many agencies whose 
activities impact floodplain use and flood damages. That mechanism exists on paper–the 
Interagency Task Force on Floodplain Management. Its functions were transferred to FEMA 
years ago, and over the years provided valuable functions to coordinate agency programs 
impacting and addressing floods. FEMA needs to re-activate that group, which has been 
dormant the past couple of years. 
These ideas are some of the positions of the ASFPM which relate to the issues you have raised in 
your background paper. We refer you to our National Flood Programs in Review 2000, for a
Floodplain Management Forum 60 
complete report on floodplain management. Please feel free to contact to assist in this effort in 
anyway. We strongly support this initiative by FEMA.
Floodplain Management Forum 61 
Doug Plasencia, P.E. 
Kimley-Horn & Associates 
When asked to prepare a statement on what should be done in floodplain management one could 
be faced with the task of condensing the writings and works of many authors, some of who are 
represented at this forum. 
However, in order for the forum to be successful, it will not be possible to examine all the issues 
that need attention. The following are a listing of action items that could be undertaken by 
FEMA recognizing the constraints of time and budgets. 
1. Current NFIP Standards- The NFIP has done an outstanding job of providing guidelines that 
have become widely accepted as the minimal threshold for construction within floodplains. 
Unfortunately these standards, while perhaps adequate for managing the risk of an insurance 
fund, fall short of what is needed for the management of floodplains. In part the problem lies 
that many local officials, and perhaps some state officials have not fully thought through the 
ramifications of permitting development that in fact does have adverse impacts on other 
properties within the floodplain, especially when massive floodplain encroachments are 
allowed. 
For the long term a thorough review of standards is required. In the near term, FEMA should 
initiate a program of education that establishes and reminds officials that the NFIP standards 
are there to manage the fund, and that FEMA would strongly urge state and local 
governments to adopt policies and standards that would reduce or eliminate flood impacts 
caused by floodplain development. This message has not been carried forward in a proactive 
manner. 
For large development initiatives perhaps this is an analysis that would mitigate for impacts 
on both increased flood stage and velocities. For small development perhaps this would 
require obtaining permission for minor impacts from adjacent property owners. 
2. Master Plans- While a no-impact floodplain regulation is desirable, it may not be practical, 
especially in growing urban areas where multiple projects are envisioned. FEMA should be 
encouraging the development of river master plans that in essence would develop the base 
line hydraulic models, that would identify mitigation actions, and that would provide for 
acceptable levels of impact. Modifications to the plan would have to be weighed in terms of 
overall impacts to the community. 
3. Residual Risk Flood Insurance- It has been documented that through the construction of 
flood control works there has been increased occupancy of floodplain areas. While protected 
to a degree from flooding, this development is at risk to devastation from large “overtopping” 
events, or by the failure of the structure. In many cases the damages and impacts will be 
more severe than if the area had been subjected to a gradual rise in floodwaters. There is a 
need to expand the flood insurance program to include the concept of residual risk insurance 
and standards.
Floodplain Management Forum 62 
Community or Project Flood Insurance- For many communities an effective mitigation tool 
would be to ensure flood insurance coverage for an entire community, for sections of a 
community, or perhaps for areas of residual risk. A community placed policy is worth 
exploring to see if in fact it could be a cost-effective option for communities. 
4. Coordination- In the past 7 years there has been many advances by individual federal 
agencies. However, at the same time, it would appear that mechanisms to ensure ongoing 
coordination of this policy area have not improved and may have become weaker. I would 
urge two actions by FEMA. 
The first is for FEMA to reinitiate the Federal Interagency Task Force on Floodplain 
Management. This group led for many years by FEMA has fallen into disuse. However, the 
influence this group had by allowing agency staff to share issues and directions was 
instrumental in laying the groundwork for many of the policy initiatives adopted in the past 
several years, and into the future. 
The second area would be for the FEMA Director to use his influence at the White House to 
urge the release of the new floodplain management executive order, and to establish a 
somewhat more senior level coordinating mechanism for policy development. 
5. State and Local Capability- During the 1990’s there has been an alarming decrease in the 
number of full service state level floodplain management programs. In many cases these 
programs have become simply a clearinghouse for information on the NFIP. On the other 
hand some local agencies have enjoyed increased funding and expansion of floodplain 
management authorities, that far exceed the capability of state government. While on one 
hand this is positive, on the other hand it has created a void in state level policy formation, 
and the necessary support for small and medium sized communities that lack resources to 
address floodplain management. 
FEMA policies are not helping this problem and in fact may be making it worse. There is an 
absolute need to bring back into the process the State Coordinator for the NFIP, and more 
important develop an approach that would broaden the mitigation focus of these individuals 
beyond the NFIP. The Flood Insurance fund and FEMA both would benefit by renewed 
capability at the state level.
Floodplain Management Forum 63 
The Regional Development Organizations 
A Natural Partnership for Sustainability 
Ed Copeland 
Floodplain Coordinator, Region II Planning and Development Council 
Background 
The National Association Of Development Organizations ( NADO ) is a leading advocate for 
a regional approach to community, economic and rural development. Founded in 1967, NADO 
provides training, information and representation for regional development organizations in 
America’s small metropolitan and rural areas. As a public interest group, NADO is also part of 
the intergovernmental partnership among federal, state, and local governments. 
NADO members, known variously as councils of governments, economic development districts, 
planning and development districts, and regional councils, provide professional and technical 
assistance to over 1,800 counties and 15,000 cities and towns. 
The majority of NADO members are Participating Communities in the NFIP 
In West Virginia, the eleven (11) Regional Planning and Development Councils were 
established in 1972 by the West Virginia State Legislature. They were founded to perform as 
local, multi-jurisdictional agencies focused specifically on regional planning and economic 
development. 
The Council’s mission involves the conversion of community and economic development needs 
into proactive strategies and plans, which then become realistic opportunities, and finally actual 
projects or programs. The Councils operate as low-key facilitators in a systematic and synergistic 
process. Their roles range from regional planning for identification and prioritization of local 
goals and objectives to maneuvering the local, state, and federal bureaucracies to pursue grants 
or project endorsements. 
The Councils are structured as locally oriented, public corporations. They are directed by elected 
officials from counties and communities within their jurisdictions, as well as non-elected 
appointees from a cross-section of a region’s social and economic institutions. Each Council 
retains a professional staff adept in public administration, regional/community planning and 
development. 
The councils represent all fifty-five ( 55 ) counties and ninety-eight ( 98 ) % of the cities in West 
Virginia. 
All fifty-five ( 55 ) counties and the majority of cities in West Virginia are Participating 
Communities in the NFIP
Floodplain Management Forum 64 
Summary 
The National Flood Insurance Program, the Map Modernization Program, and the Flood 
Insurance Program are all proactive initiatives. 
What Existing Organization is : 
· Proactive 
· Has established working relationships, on a daily basis, with the CEO’s of NFIP 
communities throughout the United States 
· Is respected as a contributing partner and the go-to organization that will leverage funding 
resources and provide technical assistance to their members in their efforts to provide 
community and economic development opportunities 
· Understands the importance of building relationships and partnerships with the same key 
players that the NFIP, Map Modernization, and the Flood Insurance Programs are marketing 
to 
· Is looking for ways to leverage funding and expertise to develop GIS mapping products for 
their communities. 
· Are continually looking for programs that will enhance their ability to make their member 
communities more disaster resistant 
· Empowers the local communities 
· Empowers the local citizenry 
· Leverages EDA, HUD, ARC, and other federal funding resources with local and private 
matches 
This organization is the Regional Planning and Development Councils ( RDO )
Floodplain Management Forum 65 
French Wetmore 
French & Associates, Ltd. 
· Like all government programs, the NFIP depends on people. There are three “classes” of 
people that need attention. 
· First is the local official 
A. Key to ensuring that new construction complies with the NFIP regulations 
B. Can encourage better practices, such as avoidance of building in the floodplain 
C. Can overcome many mapping shortcomings 
D. Can promote the purchase of flood insurance and help insurance agents 
· Second class of people is the property owner 
A. Final decision maker on how the floodplain is developed 
B. Purchaser of flood insurance policies 
C. Citizens who have an impact on local government 
· These two classes of people need training and education from the third class: the 
professionals who work with the program (us) 
A. We have some training and education tools, such as the home study course, floodplain 
manager certification and ASFPM’s guide for elected officials 
B. But we have neglected the most important tool: Community Assistance Visits 
C. Field staff need support to do the unpleasant things that are sometimes needed 
D. We need the right attitude – field staff should spend less time focusing on some of the 
minutia of the NFIP regulations and more time reaching more communities to determine 
whether local officials understand and are enforcing the basics 
· The Community Rating System is too often misunderstood and underutilized 
A. Communities use the CRS to organize their programs and to start new ones 
B. There is an underutilized field staff of ISO/CRS Specialists 
C. Local CRS public information programs may be able to help a lot of people 
· Do not issue any more map revisions based on fill 
· FEMA needs to move away from its one-track mitigation approach of funding acquisition 
A. FEMA cannot afford to buy every building that will be flooded 
B. There are many other things that a community should be doing (especially higher 
regulatory standards and stormwater management) 
C. FEMA funding should leverage good floodplain management or hazard mitigation plans 
that identify those other things and get communities to pursue them
Floodplain Management Forum 66 
Michael J. Moye 
President, Bank of America Insurance Services, Inc. 
It is a privilege and honor to have been invited to participate in this forum, both as a 
representative of Bank of America and The National Lenders’ Insurance Council. Also, I 
personally am honored to be here. I have been connected with the National Flood Insurance 
Program (NFIP) in some way since 1984 when I hired on as an Account Executive at the 
beginning of the Write Your Own (WYO) Program. In these past sixteen years, I have observed 
the progress of the program from several vantage points, i.e. government, insurance company, 
insurance agency, flood zone determination company and lending industry. 
As we look to improve the program, we must not lose sight of the great strides that have been 
made in making certain that this country’s citizens are adequately protected from the peril of 
flood, and that when the floods come, mechanisms are in place to mitigate the disaster and to 
hasten recovery 
Bank of America has a strong interest in the NFIP. The bank serves over 30 million households 
and 2 million business customers in the District of Columbia and 21 states, from coast to coast. 
One in every three households in the U.S. has a banking relationship with us. 
The National Lenders’ Insurance Council (NLIC) formed in 1994 as the “National Lenders’ 
Flood Committee” for the express purpose of providing a “lender’s perspective” to the other 
flood insurance stakeholders. Emboldened by the favorable response to the Committee’s work 
and voice, the group incorporated in 1996 as a not for profit association. 
NLIC’s published mission is to reduce insurable losses to assets for property owners through 
government/industry partnerships, education and dialogue. Our vision is for regulators, investors, 
lenders, servicers, insurers and other responsible industry members to come together to foster an 
environment in which economic hardship for property owners across the nation can be 
eliminated. Consequently, this forum complies nicely with the goals and purposes of the 
Council. 
NLIC has given voice to a lender’s perspective in a number of ways, such as creating workshops 
for the National Flood Conference, participating in FIA’s Call for Issues, providing a 
representative to attend meetings held by other stakeholders, and publishing a quarterly 
newsletter. We have taken those opportunities to express our opinions on many of the questions 
covered in the background material provided to the attendees at this forum. 
In the short time allotted, I tried to obtain a sample reaction of other lenders to the questions 
posed. Following is a summary of some of the responses, which in no way purport to be 
complete, compelling or conclusive. Perhaps they may generate thought and conversation or 
agree with other views presented.
Floodplain Management Forum 67 
Flood Hazard Identification 
· Should the mapping of floodplains be based on a higher standard, such as the 500-year 
standard? 
Yes, there is nothing magic about an A or V zone. More and more flooding occurs beyond 
these boundaries, bringing into question the validity of the standard set for mandatory 
purchase. 
Flood Zone boundaries may be more of an art than a science and the 1% standard leads 
people into a false sense of security. 
NOTE: The nomenclature alone, e.g. 500 year, creates a false notion about the threat of 
flooding. 
· How can the uncertainty in hydrology be addressed in the flood maps? 
The uncertainty needs to be recognized and addressed by creating allowances for error in the 
flood zone calculation. Admit that it’s not certain, and factor in a “conservative” measure 
for the delineation of the zone area and the base flood elevation. 
· Should mapping be based on future conditions, accounting for urbanization and coastal 
erosion? 
Absolutely! We are now faced with huge tracts of land being developed and no flood study 
done because development was not contemplated. By requiring future conditions, a 
community is compelled to consider the impacts of development. Rates can be adjusted as 
the future conditions become present conditions. 
· Does the current policy that recognizes levees or removes properties from the floodplain 
adequately reflect the flood risk? 
No. An unnamed source says that there are two kinds of levees, those that have been 
breached or broken, and those that will be breached or broken. 
· Are hazards such as coastal erosion, alluvial fans, coastal flooding, high velocity flooding, 
and similar hazards adequately addressed in the hazard identification and mapping? 
No. These special hazards require special attention and deserve a separate rating structure 
because of their unique occurrence characteristics. 
· Are current standards for designating floodways appropriate, particularly the allowance of a 
one-foot increase in flood stage? 
No, the standards need to recognize and allow for the types of impedance to the flow of water 
that occur with debris, and to recognize that hydrology calculations are really “best educated
Floodplain Management Forum 68 
guesses” based on historical data and predictive modeling. 
· Are there methods of identifying flood hazards other than the traditional mapping approach? 
Unknown 
Floodplain Management 
· Should a higher standard, such as the elevation to the 500-year flood, be implemented? 
Yes, for similar reasons stated above in Flood Hazard Identification. 
· Should freeboard be required above the base flood? 
Yes, due to the uncertainty of debris and other impacts on water flow and rise. 
· Are hazards such as coastal erosion, alluvial fans, coastal flooding, high velocity flooding, 
and similar hazards adequately addressed in the regulatory requirements? 
Unknown 
· What strategies can be developed to encourage communities to adopt hazard mitigation 
plans or comprehensive plans and policies that steer development out of floodplains? 
Re-assess responsibilities in floodplain management and demand higher accountability of 
local communities. The community needs to take a hard look at its vulnerability and act 
accordingly. It is too easy to call for disaster aid from the federal government. 
Project Impact is an important tool in helping communities face the challenge. 
· Are there other things the Program can do to increase levels of protection for flood-prone 
properties? 
One suggestion is to require local communities to notify property owners every year of the 
flood prone status of their property. They are the ones that determine what building or land 
use will be allowed that could alter the floodways. 
Also, since the flood maps benefit the community, a “hazard mapping fee” could be levied as 
a real estate property tax surcharge to help fund hazard identification. 
· What strategies and incentives can help encourage states and communities to foster 
sustainable development and discourage inappropriate floodplain development? 
Set stringent rules for government assistance following disasters; require greater participation 
up front in hazard identification, development of mitigation strategies, and creation of 
response mechanisms. Buy outs following a disaster are costly.
Floodplain Management Forum 69 
· What can be done to instill a greater sense of responsibility for states, communities, and 
citizens for inappropriate floodplain development that puts people and property at risk? 
Again, put the state, community and citizens on notice that if they fail to manage their risks 
properly, the federal government will be stingy with disaster relief, then follow through. It’s 
bad “parenting” to do otherwise. 
· What strategies can be developed to address the flood risk to structures constructed prior to 
the NFIP? 
Look at possible retro-fit options short of elevation. Re-structure the rating of insurance to 
take away subsidies (over time). Explore financial incentives to encourage homeowners and 
communities to take positive steps toward “flood proofing” such structures. 
Insurance 
· Should the mandatory flood insurance purchase requirement be extended to apply outside of 
the 100-year floodplain? Are there other ways to increase coverage in these areas? 
Most insurance is purchased because of a purchase requirement. Since the extent of flooding 
has proven to be difficult to predict, extending the mandatory purchase requirement makes 
some sense. Rate the risk as best as possible. The Preferred Rate is now inadequate because 
only people who are convinced they will be flooded buy the coverage. The rate may be 
adequate if everyone in that category were required to purchase. 
· Are there methods to improve implementation of the mandatory purchase requirement by 
federal agencies and lenders? 
Since the passage of the 1994 Flood Insurance Reform Act, the criticism that regulated 
lenders are not compliant loses its punch with every passing month. The policy count 
increase following the ’94 Act is not attributable to the salesmanship of the insurance 
industry, but to the fact that lenders have implemented or buttressed existing policies, 
procedures and systems. They not only ensure the purchase of flood insurance at origination 
when it is required, but also make certain that it is maintained for the term of the loan. 
Compliance isn’t 100%, but the trend is in the right direction. 
Still, a carrot (incentives) along with the stick (threat of penalties) could help speed the 
process along for those who are slow to recognize the value of compliance. A look at tax 
incentives or Community Reinvestment credits could be catalysts. 
· Are there ways to ensure that once purchased, flood insurance policies remain in place? 
Again, lenders and servicers have developed systems to track insurance, or have outsourced 
tracking to ensure renewal. They do so only for mandatory properties, however. If the 
mortgagee clause is correct on the policy, it should be renewed or the lender will begin a 
“lender placed insurance” process to remind the borrower that the policy must be renewed or
Floodplain Management Forum 70 
the lender will purchase the insurance to protect the loan, and charge the borrower the 
premium. 
· Are there ways to increase insurance coverage to buildings not subject to the mandatory 
purchase requirement? 
The only sure way to make it happen in great numbers is to require it. Again, most people 
don’t buy the coverage unless required, even those at the greatest risk. 
· Should flood insurance be required behind levees? 
Require the insurance. Rate the risk appropriately. 
· Is the current flood insurance rating model sufficient, or are there other methods to rate the 
flood risk? 
This is not a simple question. The question is too broad. Under the current model, adverse 
selection is a given. If the mandatory purchase requirement is extended, the spread of risk is 
greater, making it theoretically possible to lower the rate. 
Other comments received from lenders, servicers or affiliates: 
· “There was a small town in North Carolina, Princeville, that was completely wiped out when 
the flood waters exceeded their levee. They are rebuilding the levee the way it was before. 
Perhaps for levees and dams, the requirement should be raised to the 500 year floodplain and 
periodic inspections done to ensure proper maintenance to the structure if the flood insurance 
requirement is waived.” 
· “Another point that maybe should be discussed regarding NFIP is the coverage limits. Many 
properties along the coast and in special flood hazard areas are high dollar properties and the 
current coverage limit does not fully protect the property. Although excess flood insurance is 
available, many homeowners do not purchase it because they are not required and because 
the current method of processing a claim through an excess flood policy is a deterrent.” 
· “Also, if FEMA and the NFIP are trying to reduce the flood risk, the current method of 
removing the flood requirement if the property is even a few inches out of the special flood 
hazard area seems to defeat the purpose. Maybe a buffer zone of 20 feet could be established 
around the structure. Also perhaps a buffer of 1 foot in elevation before issuing a LOMA. I 
have seen cases, especially after Floyd, where the property was but a few inches or feet from 
the flood hazard so the flood requirement was not in force and a policy was not purchased 
and the homeowner was without coverage or recourse when Floyd flooded their property.” 
· “NFIP advertising should show pictures/simulations of anticipated floodways, wave heights, 
damages, and interviews with victims, etc. Use the “shock value” that live pictures now 
provide.
Floodplain Management Forum 71 
· “LOMA’s should be issued only when the structure is elevated 10 feet or more above BFE.” 
· “Change the zone designation nomenclature from 100, 500, etc. to something more 
understandable by the layperson, e.g. low, medium, high.” 
· “My feeling about the insurance issue is this. All mortgaged properties should be required to 
carry flood insurance. Properties outside of SFHA's should be charged the Preferred 
Program flat rate or some variation of it. If every mortgaged property was insured for flood, 
ultimately large and innovative property insurers would begin to offer Homeowner and 
Dwelling Fire policies with flood because they would have a proper spread of risk and could 
sell the convenience of a single policy. An expansion of the current flood requirement would 
eliminate most of the insurance problems and issues FEMA has posed. This would also 
provide an expanded policy base upon which to impose a charge to pay for new flood maps.”
Floodplain Management Forum 72 
Wendy Lathrop 
Technical Mapping Advisory Council to FEMA 
The Technical Mapping Advisory Council to FEMA was created by the 1994 National Flood 
Insurance Reform Act (NFIRA) in order to provide technical expertise to FEMA on floodplain 
mapping issues from the users of flood hazard data. The Council is completing the final of its 
five years, as established by the NFIRA. Its ten members represent a cross section of users, 
some of whom are represented individually at this roundtable today, such as USGS, the 
Association of State Floodplain Managers, Freddie Mac, the National Lenders Insurance 
Council, and the American Society of Civil Engineers. My position on the Council is as 
representative of the American Congress on Surveying and Mapping, an organization of four 
professional societies of surveyors, geodesists, cartographers, and geographic and land 
information systems specialists. But today I speak on behalf of the Council as a whole. 
The Council has prepared an Annual Report to Director Witt at the completion of each of our 
first four years, containing discussion of issues and new recommendations to be considered in 
the planning and management of FEMA's flood mapping program. Because those reports are a 
matter of public record, I will not take this group's time to review past documents. 
The Council is pleased and encouraged that many of its concerns have been incorporated into the 
Map Modernization Plan (MMP). We see this as a step forward both in responsiveness to the 
public and as a change in management style. However, we do not see the MMP as a final 
solution to improving the efficiency and enforcement of the National Flood Insurance Program, 
and view these as constantly evolving processes. I will try to summarize the focus of this year's 
discussions relating to the preparation of our final Annual Report to Director Witt. 
The Council is concerned that flood maps present a current and accurate depiction of flood 
hazard areas. This includes the following: 
· the location of identified flood prone areas (addressing base map accuracy), 
· the extent of flooding (related to hydrologic and hydraulic analyses), 
· the true severity of flooding (comparing historic flood levels to the calculated levels of 
flooding, and verifying calculated flood levels after a disaster), and 
· the variability of flooding (including factors such as dam and levee failures, alluvial fan 
shifts, areas prone to wildfires that seal the soil from absorbing water, erosion, and 
tsunamis). 
We are concerned that data provided to technical users is a complete and current picture of the 
flood hazard status of an area. But the maps are used for local approval of construction, local 
and regional emergency planning for rescue and evacuation, floodplain and stormwater 
management. Therefore floodplain maps and flood hazard data are of great importance to more 
than the small technical user population, and data must be complete and current for every 
individual or agency seeking to protect lives and property. For this reason, we believe that the 
cost of improving the accuracy and availability of flood hazard data should not fall on the 
shoulders of the few insurance policy holders within the 1% annual-chance floodplain. The
Floodplain Management Forum 73 
benefit of good mapping improves the quality of life for the entire community, and therefore of 
the entire nation. Some of the Technical Mapping Advisory Council's current concerns in 
creating useful flood risk data (not all data will continue to be traditional paper maps as we move 
into the digital age) include the following: 
· Unnumbered A-zones are approximate delineations of the Special Flood Hazard Area, and 
are a source of inconsistent interpretation of the extent and location of flood risks. Vague 
data may be better than no data, but is not the best foundation for decision making in 
planning and floodplain management. 
· There are still unstudied flood-prone areas in our nation, and these must be prioritized and 
mapped for the protection of the public. 
· The cumulative effect of Letters of Map Amendment must be acknowledged. Presently, each 
LOMA is seen as a stand-alone isolated event, and not related to the ultimate cumulative 
change in a community's flood hazard status. 
· These documents (LOMAs) must also be more easily available and incorporated into the 
floodplain mapping to ensure a complete and current picture of the flood risks in a 
community at any given time. 
· The cumulative effects of factors such as urbanization, LOMAs, wildfires, and erosion must 
be acknowledged in watershed-wide floodplain management practice. Watershed-wide 
planning must extend beyond the invisible and arbitrary boundaries of an individual 
community's corporate limits. Development within one community can affect the flood risks 
in another separately mapped community. Regional and watershed-wide planning and 
floodplain management are the only sound solutions. 
· Although crucial, public involvement in floodplain management must go beyond education 
of public officials and the citizenry. It must also include meaningful public involvement 
during the decision making process so that there is local buy-in for the adopted practices 
· Ongoing input to FEMA from groups such as the Council or today's Forum must be ongoing 
to provide feedback, air new concerns of constituents, and serve as a testing ground for 
FEMA's new products or policies. The process provides expertise and guidance to FEMA 
and earns the support of those whose concerns are heard and incorporated into FEMA 
planning and programming. 
Thank you for your time, and I look forward to a valuable exchange today.
Floodplain Management Forum 74 
Albert LeQuang 
Manager, Insurance Standards and Disaster Mitigation 
Freddie Mac 
My name is Al LeQuang. I’m responsible for insurance standards and disaster mitigation in the 
Mortgage Credit Policy Department of Freddie Mac. 
I regret that I was unable to provide you with advance copies of my remarks. I did not receive 
this invitation until late last week. I will be more than happy to send a copy to FEMA for further 
distribution to interested parties, or you can give me a business card and I’ll send it directly to 
you. 
As you may know, Freddie Mac is a stockholder-owned corporation chartered by Congress in 
1970 to create a continuous flow of funds to mortgage lenders in support of homeownership and 
rental housing. We fulfill this mandate primarily by purchasing mortgages from primary lenders 
and packaging them into mortgage-backed securities which we sell to investors here and abroad. 
By doing so, we sustain a stable mortgage credit system and ultimately lower housing costs for 
homeowners and renters. 
Over the years, we have helped open doors for one in six homebuyers and some 2 million 
renters. 
We help Americans get into homes they can afford, but we also want to get them into homes 
they can and will keep. 
Further, as a major purchaser of mortgage loans and guarantor of mortgage-backed securities, we 
deem it critical to the fulfillment of our fiduciary responsibilities that our collateral remain 
unimpaired. 
To those ends, we have established a standard requirement that all properties securing mortgages 
sold to us or serviced for us be adequately insured against losses from natural or man-made 
perils. This includes such perils as fire, windstorm, earthquakes, sinkholes, mine subsidence, 
flooding, etc. Even if there had been no laws governing flood insurance, prudent risk 
management would have compelled us to impose a requirement for such coverage. 
This is where government intervention muddies up the water, if you will. While we’re grateful 
the federal government stepped in when it did in 1968 to establish the National Flood Insurance 
Program (NFIP) and fill a void in flood insurance coverage, we must deplore what we perceive 
as the NFIP still operating, in some respects, by 1968 standards. Over the years, we have 
implored the Federal Insurance Administration (FIA) to amend certain aspects of the insurance 
coverage, but our effort has been of little avail. In the private sector, if you do not advance with 
the market, competition will kill you. The NFIP, on the other hand, has little incentive to 
change. We have had many National Flood Conferences, even a Grand Forks flood insurance 
“summit,” but very little has changed. In some respects, this can be attributed to statutory 
constraints. In other respects, program designs are at fault.
Floodplain Management Forum 75 
We thus applaud Director Witt for his leadership in convening this Forum which, in his own 
words and among other goals, will “identify aspects of the NFIP that are ripe for change” and 
“help the Federal Emergency Management Agency (FEMA) evaluate the NFIP in order to 
improve programs and policies.” 
Freddie Mac has a long history of cooperation with and support of the NFIP. That is why we 
enthusiastically responded to Director Witt’s appeal. We take this opportunity to bring to 
Director Witt and the distinguished Forum participants this core recommendation for change to 
the NFIP: for the sake of the insured homeowner, the mortgagee, the mortgage investor and the 
taxpayer at large, flood insurance coverage must be made to perform like homeowners coverage. 
While the insurance industry has eliminated coinsurance penalties by insuring only to value (i.e., 
for 100 percent of replacement cost), the NFIP’s insurance contract still contains a penalty for 
insuring for less than 80 percent of replacement cost. We thus have a situation where, on one 
hand, the law essentially tells homeowners (but, mind you, only homeowners who have a 
mortgage with a federally-regulated lender or a mortgage that will be sold to Freddie Mac or 
Fannie Mae): “we only need you to insure for the loan amount,” but, on the other hand, the 
NFIP’s insurance contract essentially says, “if you do that, I’m not going to make you whole 
when you file a claim.” 
If you have a property with a replacement cost value of $100,000 on which there is a $50,000 
mortgage and you buy only the minimum required by law, your claim for loss is not paid in full, 
as explained above. Where do you go, then? Federal disaster assistance. This does not 
reconcile with Director Witt’s philosophy that flood insurance is “an essential mechanism of 
transferring the costs of flood losses from the taxpayers to property owners” and “helps cultivate 
individual responsibility.” Neither the flood insurance statutes nor the implementing regulations 
of FEMA and the banking regulatory agencies promote this individual responsibility. 
Freddie Mac, for its own protection and for the sake of its borrowers, require the latter to insure 
for the greater of the loan amount or the NFIP insurance contract’s minimum of 80 percent of 
replacement cost. However, it has been an uphill battle for us to convince both our borrowers 
and our lenders that the borrowers need to insure for more than the minimum required by federal 
statutes. There’s even been at least one court decision that the coverage required by federal 
statutes is the maximum that may be required of a borrower. Again, in the private sector, 
customer satisfaction drives our operations. It may ultimately cause us to ease up on our flood 
insurance requirements but we certainly would not be the only loser. If the NFIP does not 
change and we do, you can expect to see less premium dollars flowing into the Insurance Fund 
and more taxpayers’ dollars flowing out of federal disaster assistance. Not to mention a rise in 
the incidence of mortgage default resulting from uncompensated flood losses. 
Additional Living Expenses (ALE) is another coverage that the NFIP should assume, just as the 
standard homeowners insurance policy does. We cannot see why insured flood victims should 
continue to look to federal disaster assistance for their temporary housing needs.
Floodplain Management Forum 76 
There are many other aspects of the flood insurance coverage that, in our opinion, need to be 
brought to current industry standards. For example: coverage for co-operative buildings; 
coverage limits for multifamily rental buildings; inflation guard; condominiums; zone ratings, 
etc. Because of time constraints, I will not expand upon them at this time. I would be more than 
happy to discuss those issues in the course of the Forum, or later on with interested FEMA/FIA 
officials. 
Thanks again for giving Freddie Mac this opportunity.
Floodplain Management Forum 77 
Permitting Disaster in America 
Brett Hulsey 
Director, Protect Our Families From Floods Project 
Sierra Club Midwest Office 
My Background 
· Sierra Club Senior Midwest Representative 
· Directs Protect Our Families from Floods Project 
· Masters in Natural Science and Geography, O.U., B.A. in Political Economy from 
Middlebury College 
· Dane County Board Supervisor, member Lakes and Watersheds Commission, Transportation 
and Land Conservation Committees 
· Winner, FEMA Distinguished Public Service Award 
· Former teacher and VISTA Volunteer 
Overview 
· Thanks for your leadership on Nationwide Permits and Project Impact. 
· A positive vision and values. 
· Army Corps reforms in the right direction. 
· Flood deaths and damage increasing. 
· Smart growth = reduced floodplains sprawl and “rubber stamp” wetland destruction. 
· Need more help stopping bad projects and protecting open space. 
Sierra Club Principles of Flood Protection 
· Help those flooded recover and move out of harms’ way. 
· Protect wetlands, floodplains, and other critical habitat upstream to store water and reduce 
future flood risks. 
· Strengthen floodplain protections to keep others from moving into harms’ way. 
· Top priority of the national sprawl campaign 
Key Values that Relate to Wetland Destruction and Floodplain Sprawl 
· Responsibility to protect ourselves and families from floods 
· Responsibility to protect our environment, land and water 
· Responsibility to plan and spend tax money wisely
Floodplain Management Forum 78 
The Message—Don’t Permit Disaster in Floodplains, Wetlands 
· Floodplains sprawl hurts us all with more flood deaths and risks. 
· Out-of-control, irresponsible building threatens our quality of life and our environment. 
· Don’t build in wetlands and floodplains. 
· Need Feds to do their part to slow floodplain sprawl. 
· State and local leaders need to slow floodplain permitting. 
Thanks for the Help on “Rubber Stamp” Destruction 
· Nationwide Permits (NWPs), the easy wetland destruction permit, allows developers to 
destroy small wetlands with: 
–No warning neighbors of future flood risks. 
–No mitigating wetlands elsewhere. 
–Little oversight. 
· 99% permits granted in 16 days. 
· Resulting in the drainage and destruction of 78,065 acres between 1988-96. Like blowing up 
24,000 small flood control dams. 
Flooding Facts and Concerns 
Floods have caused greater loss of life and property, and disrupted more families than 
all other natural hazards combined.” 
-FEMA Director James Lee Witt 
· Deaths and Damages 
· Wetland Benefits 
· Destruction Rates Increasing Likelihood of Flooding 
Top Ten Flood States 
1. Texas 145 
2. Missouri 64 
3. Ohio 60 
4. California 69 
5. Georgia 49 
6. Kentucky 38 
7. Tennessee 37 
8. Alabama/Penn. 32 
Source: US Army Corps of Engineers
Floodplain Management Forum 79 
Top Flood Damage States=High Wetland Destruction States 
1. Iowa $6.7 billion 89% lost 
2. California $4.5 92% 
3. North Dakota $3.9 49(75)% 
4. Louisiana $3.8 46% 
5. Missouri $3.5 87% 
6. Oregon $3.4 38% 
7. Illinois $2.9 85% 
8. Texas $2.0 52% 
Average $3.8 67% 
National Average $0.9 53% 
Need to Focus Efforts on Top Flood Disaster Counties 
· 7 declarations--King County WA, Jefferson County IN 
· 6 declarations--Grays Harbor, Lewis, Pierce, Snohomish, Thurston County WA, 
Dearborn and Switzerland County IN, Marshall County AL, Oxford County ME. 
· 5 declarations--WA, IN, AL, ME, ND, CA, SD, IL, VT, MO. 
How Does Floodplain Sprawl Hurt Us More Than Flood Deaths and Damage? 
· Flooding killed more than 957 people from ‘89-98, according to USACE. 
· Flooding has caused millions of people to become homeless. 
· Flooding cost $4.5-8 billion each year since 1988, USACE/NOAA. 
Wetlands Can Reduce Floods 
“Where significant wetlands exist, they can have a noticeable effect on (flood) discharge 
peaks from the (Mississippi River) basin.” 
“The Galloway Report,” A Blueprint for Change, Part V, Science of Floodplain 
Management into the 21st Century 
Wetlands Could Soak up ’93 Flood 
“The 1993 flood verifies the need for additional wetland the amount of excess water that 
passed St. Louis during the 1993 flood would have covered a little more than 13 million 
acres -- half of the wetland acreage drained since 1780 in the upper Mississippi Basin. By 
strategically placing 13 million acres of wetlands on hydric soils in the Basin, we can 
solve the Basin’s flooding problem in an ecologically sound manner.” 
--Hey, Don, "Commentary: Flood Reduction through Wetland Restoration," 
Restoration Ecology, Volume 3, No. 1, page 4.
Floodplain Management Forum 80 
Stopping Floodplain Sprawl Cheaper Than Buyouts 
· FEMA, state emergency management agencies and local governments have moved more than 
17,000 homes and businesses out of floodplains from 1988-98. 
· These bailouts cost federal taxpayers more than $700 million since1988. 
· That money would have bought easements on 700,000 acres of wetlands = 2.1 million acrefeet 
storage. 
· Flood insurance running $300+ million deficit each year. 
Flood Hazard Identification 
· Should the mapping of floodplains based on a higher standard, such as the 500-year 
standard? YES, BUT START WITH 100 YR IN HIGH FLOOD COUNTIES, MAKE PART 
OF FLOOD PACKAGE 
· How can the uncertainty in hydrology be addressed in the flood maps? MAP NOW, TALK 
LATER. 
· Should mapping be based on future conditions, accounting for urbanization and coastal 
erosion? YES 
· Does the current policy that recognizes levees or removes properties from the floodplain 
adequately reflect the flood risk? NO, I.E. MISS RIVER, DxD report. 
· Are hazards such as coastal erosion, alluvial fans, coastal flooding, high velocity flooding, 
and similar hazards adequately addressed in the hazard identification and mapping? NO 
· Are current standards for designating floodways appropriate, particularly the allowance of a 
one-foot increase in flood stage? NO 1’ RISE SHOULD BE ALLOWED, LOOK AT THE 
PHILLY SITUATION. 
· Are there methods of identifying flood hazards other than the traditional mapping approach? 
HIGH, MED, LOW HAZARD ZONES WOULD BE HELPFUL. 
· Should a higher standard, such as the elevation to the 500-year flood, be implemented? YES. 
· Should freeboard be required above the base flood? YES, AT LEASE THREE FEET. 
· Are hazards such as coastal erosion, alluvial fans, coastal flooding, high velocity flooding, 
and similar hazards adequately addressed in the regulatory requirements? NO. 
· What strategies can be developed to encourage communities to adopt hazard mitigation plans 
or comprehensive plans and policies that steer development out of floodplains? MAKE
Floodplain Management Forum 81 
THEM RESPONSIBLE FOR DEV. IN THOSE AREAS, REQUIRE PAYBACK IF AREAS 
NOT PROTECTED. 
· What strategies and incentives can help encourage states and communities to foster 
sustainable development and discourage inappropriate floodplain development? MAKE 
THEM CONDITIONS OF ASSISTANCE. 
· Are there other things the Program can do to increase levels of protection for flood-prone 
properties? REQUIRE POSTING ON REAL ESTATE SIGN IN HIGH HAZARD AREAS. 
· What can be done to instill a greater sense of responsibility for states, communities, and 
citizens for inappropriate floodplain development that puts people and property at risk? 
REDUCE THE SUBSIDIES. 
· What strategies can be developed to address the flood risk to structures constructed prior to 
the NFIP? BUY THEM OUT. 
Insurance 
· Should the mandatory flood insurance purchase requirement be extended to apply outside of 
the 100-year floodplain? Are there other ways to increase coverage in these areas? YES 
· Are there methods to improve implementation of the mandatory purchase requirement by 
federal agencies and lenders? SPOT AUDITS IN HIGH FLOOD AREAS. 
· Are there ways to ensure that once purchased, flood insurance policies remain in place? 
SPOT CHECKS. 
· Are there ways to increase insurance coverage to buildings not subject to the mandatory 
purchase requirement? ADS DON’T SEEM TO WORK. 
· Should flood insurance be required behind levees? YES. 
· Is the current flood insurance rating model sufficient, or are there other methods to rate the 
flood risk? SHOULD BE ACTUARIALLY SOUND. Reduce flood damages and death by: 
A. Protecting floodplains, wetlands, and coastal areas from sprawl development through 
protection, regulation, and purchase. 
B. FEMA and state floodplain office should review all wetland destruction permits in high 
flood counties. 
C. Updating all 100 year flood maps at time of disaster. 
D. Support Wetlands Reserve Program, wildlife refuge expansion, and other habitat 
programs more vigorously.
Floodplain Management Forum 82 
Dr. Gilbert F. White 
Institute of Behavioral Science 
University of Colorado 
The aim of FEMA to focus on large issues facing the NFIP and floodplain management is 
commendable and belatedly timely. The major intent “to explain methods to increase the level 
of protection against flood risks” is of doubtful suitability unless based upon a careful appraisal 
of national experience in floodplain management and unless linked with an effort to involve all 
interested responsible government and community organizations in cooperative actions to 
promote wise public and private use of hazardous areas. 
The Federal interagency task force that was one of the two groups recommending establishment 
of a national flood insurance program in 1966 proposed that such a venture be experimental and 
subject to critical appraisal as a means of avoiding its becoming counter-productive (89th 
Congress, 2d session, House Document No. 465, 1966, A United National Program for 
Managing Flood Losses, 16-18, 38-39). There has not yet been a thorough evaluation of the 
effects of the national flood insurance program, although a review of all the available scattered 
research finding was initiated by the FIA Administrator in 1998, and there have been recent 
studies of selected coastal counties by the Heinz Center, and of Tampa and Syracuse floodplains 
by Tobin and Montz (in press) supported by the Compton Foundation. Thus, there is not yet a 
solid base for sweeping generalizations about how and why the NFIP affects national efficiency 
and vulnerability. 
The focus on “increasing the level of protection against flood risks” tends to ignore the more 
fundamental aim of promoting the development of genuinely sustainable communities (Mileti, 
Disaster by Design, 1999). To address that goal would, as a minimum, require explicit attention 
to natural and productive uses of floodplains. It also would require attention to other natural 
hazard and disaster relief policies in similar areas as begun in the Project Impact studies. Both of 
these requirements would involve careful analysis of: the influence on land use and hazard 
vulnerability; of the policies and practices of a wide range of government agencies, such as, 
Federal public roads and open space agencies (e.g. OMB, Federal Programs Offering Non- 
Structural Flood Recovery and Floodplain Management Alternative, 1998); and local planning 
agencies.
Floodplain Management Forum 83 
Sue Cameron 
Tillamook County Commissioner 
Tillamook County, OR 
Tillamook County, Oregon is rural County located on the northwest coast of Oregon. Rivers 
running out of the Coast Range of mountains cross a narrow coastal plain before entering the 
Pacific Ocean via one of five estuaries. Heavy winter rains characterize Tillamook's climate, 
with over 100 inches annually falling in the Coast Range. Tillamook also has 55 miles of ocean 
shoreline subject to heavy surf during the winter months, resulting in periodic bouts of flooding 
and erosion. One may easily understand, given our location and climate, that we have an active 
interest in sustainable floodplain management. 
We are encouraged that the National Flood Insurance Program (NFEP) is taking steps toward a 
more holistic approach to floodplain management. We feel that it is necessary to take steps 
beyond regulation of structures in order to reduce the risk of damage due to floods and other 
natural hazards. For example we are working with the Army Corps of Engineers on a feasibility 
study for the Tillamook Bay watershed to identify opportunities to restore wetlands and tidal 
sloughs. Such actions will improve floodplain capacity and connectivity and also improve habitat 
for fish and wildlife, including threatened and endangered salmonid species. We have also had 
great success elevating high-risk structures onto new foundations using funds from the Hazard 
Mitigation Grant Program through Oregon Emergency Management and FEMA. We feel it is 
very important to link floodplain management to floodplain health. 
Nonetheless, we have gone beyond the NFIP standards for our floodplain management 
ordinance. Our recent flooding experience has led us to question the reliability of the Flood 
Insurance Rate Maps (FIRM’s) for predicting actual floodwater depths. We now require new 
construction to be elevated three feet above the base flood elevation listed on the FIRMS. We 
have also adopted a repetitive loss provision to break the cycle of loss/insurance 
payout/loss/insurance payout due to repeated flood events. We are also working on our 
application for entry into the Community Rating System and we are a Project Impact 
community. 
Specific to the issues of flood hazard identification, floodplain management, and insurance, we 
have the following comments. 
Flood Hazard Identification 
· We support the current standard of 1% (i.e. 100-year event) for flood risk mapping and 
regulation. We feel it is helpful to have the lower risk "500-year" floodplain mapped, since 
this delineation provides additional information for property owners to use when assessing 
property values and as an area where it may be recommended but not required to use 
construction techniques which reduce flood risk. 
· We feel that mapping should be based on the best available information to create accurate 
representations of the floodplain and water depths as they currently exist. The added 
uncertainty introduced by mapping future conditions seems unwarranted and unsupportable
Floodplain Management Forum 84 
by current mapping methods. The use of more robust hydrodynamic models and alternative 
data sources, such as soil types, should be explored. 
· The mapping of coastal hazards is incomplete on the Tillamook County shoreline and we 
would like to see that completed. The methods used to generate the existing maps is not 
based on the conditions encountered on the Pacific NW coastline, particularly regarding the 
wave record used, the degree of flood protection afforded by foredunes for interior areas, and 
the risk of landslides caused by erosion of ocean bluffs during large storm events. 
· The designation of floodways is error prone and incomplete on the tidally influenced, multichannel, 
drowned river mouths commonly found in coastal Oregon. Floodways in general 
appear to be artificial, model-driven, engineering solutions rather than an accurate 
representation of where development should be restricted in order to prevent obstruction of 
floodwater discharge. 
Floodplain Management 
· As stated above, we feel the current standard is appropriate for floodplain regulations. We do 
require a 3-foot freeboard above the base flood elevation in order to deal with mapping error 
and possibly increased risk of flooding due to physical changes in our watersheds and 
floodplains. 
· We feel that there should be a renewed interest in identifying coastal hazard areas, including 
areas subject to velocity flooding and coastal erosion. However, 
regulations in these areas should be designed to eliminate subsidies for development in high 
risk areas rather than protection from the consequences of risky siting decisions. We feel that 
increased funding for risk-reducing floodplain activities should be made available. For 
example, funds for elevating structures and acquiring properties in high risk areas is very 
effective at reducing overall floodplain risk. 
Insurance 
· As a floodplain community, we are not directly involved in insurance program. However, we 
do not support extending mandatory purchase of insurance to areas outside of the 100-year 
floodplain.
Floodplain Management Forum 85 
Mike Ellegood 
Chief Engineer and General Manager of the Flood Control District 
Maricopa County, AZ 
Hello. I'm Mike Ellegood, Chief Engineer and General Manager of the Flood Control District of 
Maricopa County, which is located in the Phoenix metropolitan area. The County takes in more 
than 9,600 square miles and vies with Clark County, Nev. as the fastest growing county in the 
nation. A special challenge for our District is educating our public of the need for flood control 
when we live in a desert and only get about eight inches of rain annually. This is a continuing 
effort since most of our new residents are arriving from outside the desert southwest. 
For the last three years, the Flood Control District of Maricopa County has 
adopted what we call the "kinder, gentler" approach to flood control. Whenever possible we use 
non-structural means to mitigate the flood hazard. We work to protect the environment and 
improve the quality of life of area residents, by retaining our watercourses in as natural a 
condition as we can and by using natures facilities as parks and open space. Where a structural 
alternative is required, we typically soften its impact by making the facility dual use and 
including a recreational component into the design. 
This approach makes it much easier for us to convince the public and our municipal partners of 
the need and value of flood control facilities. By avoiding concrete, we can partner with the cities 
to plan parks, golf courses and trails alongside our floodways and washes. The cities find they 
can get two uses for a channel or basin rather than one - they can keep their residents safe while 
at the same time providing recreational amenities and open space. 
While our first instinct is to choose non-structural alternatives as a preferred method of 
mitigation, this is not always possible. Broad areas of sheet flow, existing development and 
sometimes because development is occurring in such a widespread and rapid fashion, we cannot 
always keep our planning ahead of development, structural alternatives are necessary. It is 
important to realize that a non-structural approach cannot be used as the only acceptable method 
of flood mitigation. We must retain both structural and non-structural methods as tools in our 
box. We must be able to choose the alternative that best mitigates whatever flooding issue we are 
facing. 
The question has been asked, "should design flood be increased from 100 to 500 years?" The 
Flood Control District of Maricopa County recommends that each watershed and each water 
course be studied to evaluate the degree of hazard and that an appropriate level of protection be 
adopted for each. While 500-year protection seems reasonable for our major dams and for 
watercourses such as the Mississippi and Colorado, such a return frequency would not be 
practical in Maricopa County, indeed most of Phoenix would have to be abandoned! In many 
cases, we have found that a 10-year system may be the best, most cost-effective method to 
convey water from some neighborhoods, especially those older locations where we must retrofit 
channels. Hydrologists could perform uncertainty analysis to assign the probability of danger for 
these areas and tailor our solutions accordingly. I think it is important that we design guidelines 
for this..
Floodplain Management Forum 86 
An important flood hazard that return frequencies do not address is erosion. In some of our 
watercourses in the desert southwest, the erosion hazard is every bit as dangerous as flooding. 
Erosion setbacks are necessary to provide adequate protection to the homeowner. While it can be 
properly argued that local knowledge should result in local regulations, property rights advocates 
will often successfully argue that simply elevating and staying out of the floodway will meet 
FEMA regulations and therefore should be allowed. 
Solid planning is crucial to what we do. The hazards due to flooding and erosion must be 
evaluated by watershed and watercourse and a plan developed and adopted that reflects the 
degree of hazard present. FEMA can help with this by reviewing our Area Drainage Master 
Plans and our Watercourse Master Plans and by providing a federal imprimatur to the completed 
planning effort. In Maricopa County, we are developing Watercourse and Area Drainage Master 
Plans which not only tell us the hydrology and geomorphology of the County, they also provide 
us with information regarding multi-use opportunities and potential land uses. Through these 
studies, we can determine hazardous areas, places where 10-year facilities are appropriate and 
locations where a 100-year minimum structure are mandatory. We can determine where we 
should purchase land, and where we should ask cities to curb development. These studies will 
literally map the future of our county. 
Much of the country needs updated floodplain maps. It should remain a top priority for FEMA to 
fund the map modernization program, to include the use of general funds if necessary. These 
maps should be prepared in electronic format and should be disseminated widely through the 
internet. 
We suggest that one way to fund these projects may be to mandate low-cost flood insurance for 
all homes with mortgages. As we understand that approximately 35 percent of homes damaged 
in floods are not in traditional floodplains, this could be a service to homeowners. At the same 
time, it would increase the amount of cash available to FEMA. 
But perhaps the best flood control we can practice, is simply educating the public. People need to 
understand that floods are the most likely hazard they will face in their lifetimes. They need to 
understand the importance of knowing whether they live in a floodplain and what is required if 
they do. They should understand the hydrology of the land they live on, just as they should know 
its history. As floodplain managers, we need to set aside time and money to teach the residents of 
our communities to stay out of washes during rainy seasons. 
We must never forget that our primary mission is to keep Americans safe from the dangers of 
floods. We must educate our elected officials that floods are a real hazard, and that paying for 
protective facilities is as important to safety as building jails. We can only do this through 
diligent communication with all elements of our community. I thank you for your time.
Floodplain Management Forum 87 
John R. Sheaffer, Ph.D 
Sheaffer International 
'I'he National Flood Insurance: Program (NFIP) addresses a very limited part of a watershed or 
drainage basin, the 100-ycar floodplain. 'I'here have been several studies that have speculated 
that ten percent of a watershed is subject to inundation. In addition, the focus of the NFIP is 
further limited to developed areas. The agricultural uses of the floodplain generally are not 
addressed by NFIP. Consequently, NFIP is to foster sound floodplain management and 
sustainable development while working with a relatively small portion of the watershed area; the, 
area subject to inundation from the 100-year flood, 
Rainfall occurs over all the land area of a watershed. The amount of rainfall is relatively 
uniform. The runoff from the high land, the dominant land, flows onto the low land, the servient 
land (floodplains). Because the high lands discharge onto the low lands, it is generally assumed 
that the urbanization of a watershed will increase the elevations of the 100-year flood. However, 
there is some evidence that runoff from the dominant land cannot be discharged onto the lower 
land at a rate greater than the historic flood and the point of discharge cannot be changed. 
If the dominant lands would detain or retain the rainfall that falls on them, the floodplain lands 
would not be subject to higher floods. If dominant landowners simply discharge all their runoff 
onto the servient land (floodplain), they should to be assessed for the cost of storage provided on 
the floodplains. 
In 1998, there were 68 million single-family houses in the United States. If each one of these 
houses paid a flat sum for the management of runoff, for example, $50.00 per year, $3.4 billion 
would be collected (68,000,000 x $50). This sum would be adequate to not only cover the cost 
of flood disasters, but also establish a sum of' money needed to correct past land use mistakes. 
Repetitive loss structures could be removed and sufficient funds would be available to assure that 
the occupance of floodplains would be limited to “wise uses”. 
Sewage treatment facilities are generally located on floodplains. Currently an effort is made to 
protect the treatment facilities against the 100-year flood. Success with this effort has been 
mixed. The greater floods affect adversely the “protected facilities.” Sewage treatment plants do 
not have to be located on the floodplains. In the North Fork of the Shenandoah River Basin, a 
new Modular Reclamation and Reuse System will replace four (4) sewage treatment plants that 
are located on the floodplain, eliminate the direct discharge of pollutants into the river, and 
provide the basis for a riverine greenway. The system also will remove 321,000 pounds of 
Nitrogen and Phosphorus from the Chesapeake Bay each year. 
An appraisal of the, current National Flood Insurance Program is summarized in Table 1. A 
multi-purpose approach is juxtaposed to the current effort to show the potential for expanding the 
benefits that would accrue from a broader program.
Floodplain Management Forum 88 
Table 1: Appraisal of the Current Program 
Regulatory Approach Multi-Purpose Approach 
1. Minimize flood losses (loss reduction) 1. Optimize net social benefits from 
floodplain resources (wise use of 
resources) 
2. Expand flood delineation mapping 2. Incorporate other agency efforts 
efforts (update the maps) to achieve natural and beneficial 
uses of floodplains (impact the 
hydrology) 
3. Expand participation in the flood 3. Foster sustainability, while 
insurance program (adverse selection reducing flood vulnerability 
which results in repetitive flood losses)
Floodplain Management Forum 89 
Phil Oshida 
Deputy Director 
Wetlands Division 
U.S. Environmental Protection Agency 
The U.S. Environmental Protection Agency is dedicated to protecting human health and 
safeguarding the natural environment - air, water and land - upon which life depends. 
EPA ensures that: all Americans are protected from significant risks to human health and to the 
environment where they live, learn and play; national efforts to reduce environmental risks are 
based on accurate information and the best scientific data; and Federal laws protecting human 
health and the environment are enforced fairly and effectively. 
EPA's water programs protect the public health of all Americans by ensuring safe drinking water 
and protecting the biological, physical, and chemical integrity of our nation's waters. The water 
programs protect public health and restore our nation's waters by: implementing environmental 
laws; setting strong goals; furnishing training, guidance and technical tools; and providing states, 
tribes, communities and landowners with effective environmental information and resources. 
The Environmental Protection Agency and the Federal Emergency Management Agency have 
been active partners in several activities and programs. EPA assists in the federal response to 
disasters that affect environmental infrastructure, including water supply and wastewater 
facilities. FEMA, EPA and other agencies often work together to improve floodplain 
management programs and decision making. In recent revisions to the Clean Water Act section 
404 Nationwide Permit program, FEMA and EPA worked with the Corps to develop more 
environmentally appropriate permitting requirements in floodplains and floodways. 
There are many opportunities where increased interagency collaboration would better protect and 
improve our nation's waters and floodplains, and concurrently reduce risks from flooding. FEMA 
and EPA's water programs are actively promoting interagency coordination in Headquarters and 
our Regions to enhance the environmental health of watersheds and reduce risks from flooding. 
Interagency coordination and cooperation in all areas affecting disaster risk reduction and 
environmental improvements are being encouraged. For example, EPA staff has recently 
participated in FEMA's national and regional Project Impact coordinators meetings, and FEMA 
leaders are faculty for EPA/OPM's Watershed Partnership Seminars. 
It is difficult to separate National Flood Insurance Program policies and practices from FEMA's 
larger role of reducing loss of life and property and protecting the nation's critical infrastructure 
from all types of hazards. Thus, the following recommendations may reach beyond the scope of 
the NFIP and address broader FEMA or other federal flood protection policies: 
Incentives and Disincentives 
· The federal agencies should provide increased funding and technical assistance (e.g., Project 
Impact) to states, tribes and communities that are interested in creating 
multilevel, community-based partnerships to develop comprehensive watershed
Floodplain Management Forum 90 
solutions for reducing flood damage and protecting and restoring the natural and beneficial 
functions of floodplains. 
· Concurrently, the federal government should begin to limit sources for compensation and 
after-the fact solutions to flooding problems. Larger shares of flood disaster relief should 
only be available to states, tribes and local governments that have comprehensive plans for, 
and have made significant progress in implementing strong flood risk reduction and 
environmentally sound floodplain management programs before flood disasters. 
· FEMA should revise flood insurance rate schedules and community participation standards 
for the National Flood Insurance Program to provide increased incentives to reduce flood 
risks. FEMA's flood insurance underwriting should be modified to more closely resemble the 
standards of the private insurance industry. When structures have been repetitively damaged 
by floods, flood insurance premium rates should be increased to reflect the higher flood 
frequency and cumulative cost of flood losses associated with that property. 
Education and Outreach 
· Education and outreach should be improved to provide communities better information on 
current and future flood risks, and the nonstructural alternatives for reducing risks. 
· The public needs to be able to easily determine whether their homes and jobs are in the 
floodplain or floodway (e.g., using Internet sites or real estate transactions/records). 
· Communities need to understand how future buildout plans for areas upstream, in the 
floodplain and/or in the watershed may increase their risks. As an example, EPA and FEMA 
can work with state and local community representatives to determine the effects reduced 
permeability (increasing buildout) in the watershed will cause in terms of stream health and 
integrity, and increased risks from flooding. 
· The public should be aware of the full costs of floods (including considerations of property 
damage, human health and safety, loss of business and economic recovery, and economic 
competitiveness), and the economic and intrinsic values of open space (fish and wildlife 
habitat, improved water quality, recreation, agriculture, aesthetics and flood management). 
Restoring Floodplain 
· Federal, state, tribal and local funding for programs that increase flood storage in 
environmentally appropriate ways should be increased. Efforts such as the Wetlands Reserve, 
Emergency Wetlands Reserve, and Conservation Reserve Programs restore wetlands and 
other natural systems, and in so doing, often increase the flood -capacity of the watersheds, 
decrease the risks from flooding, and reduce the peak flows and increase the base flows of 
the streams.
Floodplain Management Forum 91 
Promoting Non-Structural Alternatives 
· The federal government should provide a clear national policy and set appropriate goals for 
floodplain management that supports and catalyzes programs that reduce risks from flooding 
through the use of nonstructural flood control alternatives. 
· Future federal expenditures and financial assistance in undeveloped floodplains that 
encourage structures in floodplains should be limited. 
· FEMA should develop, and has in place prior to a presidentially declared disaster, a national 
policy that would ensure that there is appropriate environmental review in a post flood 
disaster "emergency" situation for any proposed structural solutions to “control" future 
flooding problems. The ecological integrity of streams and other waterways should not be 
compromised in the name of "disaster relief." 
· The federal government should establish a clear preference for the nonstructural alternatives 
for flood reduction in the Economic and Environmental Principles and Guidelines for Water 
and Related Land Resources Implementation Studies. 
· The Administration should finalize and implement the Executive Order #11988 on 
Floodplain Management. 
Coordination on CWA Section 404 permits 
· FEMA should provide comments on Section 404 permit applications that affect floodplain 
and/or floodway hydrology (e.g., projects not meeting an appropriate "rise" standard for 
floodway fill and construction). The construction of such projects may significantly impact 
flood flows, increase flood risks and/or aquatic resources. FEMA experts could address caseby-
case and cumulative flood flow and risk issues. 
· FEMA should work with the Corps and EPA to help develop case-by-case mitigation 
conditions that fully offset lost conveyance and retention function of the floodplain. 
· FEMA should work with the Corps and EPA to help develop program guidance that 
emphasizes the need to avoid and minimize impacts that significantly affect flood risks 
and/or floodplain hydrology (e.g., projects not meeting an appropriate “rise" standard for 
floodway fill and construction).
Floodplain Management Forum 92 
Dr. James Berry 
Department of Biology 
Elmhurst College 
Development in mapped floodplains to a very large extent entails a known risk. In most 
enterprises in life, people who undertake known risks, such as investing in the stock market, live 
with those consequences and do not expect the public to compensate their losses. Throughout 
most of U.S. history, property owners who suffered losses from natural disasters did not expect 
the federal government to bail them; no formal system of federal disaster relief was even enacted 
until 1950. Nonetheless, disaster assistance has come to be an expectation disconnected from 
either landowners' responsibility to avoid undue risks or governmental authority to use land-use 
regulations to prevent harm to the environment or the community. We cannot afford to 
encourage the idea that there is a free lunch with regard to developing in the path if natural 
hazards. 
Today, however, court cases and a political movement seeking new takings legislation to force 
government to compensate for what property rights advocates consider excessive government 
regulation have given some local government officials pause in considering new or expanded 
programs to reduce risks from natural hazards. 
In the case of the National Flood Insurance Program, however, there simply is no constitutionally 
proscribed taking involved. The buyout program is purely voluntary, involving only willing 
sellers and willing buyers-usually local or state government. While the insurance program entails 
some regulations, these are in effect no different from the conditions and incentives built into 
private insurance, where one purchases guarantees of coverage with certain conditions imposed 
by the insurer to contain the degree of risk within reasonable bounds. If anything, the NFIP has 
at times been criticized for not being strict enough in protecting the federal government's 
interests in reducing losses. 
Local governments implement the floodplain management requirements of the NFIP as a 
condition of participation for the benefit of their own residents and property owners. This is a 
perfectly reasonable exchange. In doing so, these local governments are performing the 
important function of protecting public safety. In an effort to minimize risk for their residents, 
many communities enact stricter controls over floodplain land uses than the NFIP requires, often 
doing so as a result of incentives in the Community Rating System. They must, of course, follow 
widely recommended standards for substantive and procedural due process in order to avoid 
potential takings claims while enacting and enforcing land-use controls. There must be a sound 
factual basis for regulations as well as a means of appeal for property owners who feel they can 
establish undue economic hardship because of the regulations. 
But in the case of flood loss reduction, one development may impact the security of other 
property owners within the watershed. Examples abound. One person's unrestricted right to 
develop in a coastal zone or riverine floodplain, given the speed of hurricane winds or flash flood 
waters, can become his neighbor's flying or floating projectile. At the very least, by creating new 
impervious surface or new impediments to the flow of flood waters, new development often
Floodplain Management Forum 93 
raises the previously established topographic level of the 100-year floodplain downstream. In 
addition, the hundreds of thousands of bloated animal carcasses floating in floodwaters in North 
Carolina following Hurricane Floyd are hardly the only example of potentially serious public 
health consequences arising from questionable land-use practices. In all these cases, there is 
little question concerning the validity of the underlying public purpose of better floodplain landuse 
regulations and little basis in sound public policy for allowing or encouraging unwise 
floodplain development. Planning can be used to help communities sort out their priorities for 
achieving environmental protection, reduction in lose lives and property damage from natural 
disasters, the preservation of publicly accessible waterfront recreational opportunities, and a 
higher quality of life for the community in general. The very idea of good planning is to make 
sound, well-researched public decisions about what constitutes permissible land use with an eye 
to what measures will improve community welfare for the foreseeable future.
Floodplain Management Forum 94 
Richard Krimm 
Retired, Federal Emergency Management Agency 
On the National Archives Building in Washington there is an inscription which reads "THE 
PAST IS PROLOGUE. " One needs to look back at the reason for the National Flood Insurance 
Program before starting to look at what the future of the program should be. The intent was to 
make previously unavailable flood insurance available to residents of floodplains in return for a 
community' adoption and enforcement of floodplain management in order to reduce future losses 
from floods. Although the program has had many successes, it also has had some failures. I hope 
the recommendations from this forum will lead to a better and stronger program. 
Everything in the National Flood Insurance Program emanates from the flood insurance maps. 
These maps provide the information for insurance agents to sell insurance and more importantly 
provide the tool for floodplain management. However, the manner in which the maps are 
produced has not changed very much since 1970 when the mapping began in full force. It is of 
the greatest importance that the Federal Emergency Management Agency's Map Modernization 
Program be given adequate funding to take advantage of the modern technology available to 
improve the appearance and availability of the maps. One should be able to pull up a map on a 
computer and the maps should be able to be changed by a local government as changes occur in 
the floodplain without a major re-mapping effort. The Federal Emergency Management Agency 
(FEMA) must make the map modernization program its number one budget priority. I realize the 
difficulty of convincing the Office of Management and Budget and the Congress of such a large 
expenditure. It is going to require an extreme effort by FEMA, the Association of State 
Floodplain Managers, the insurance industry and other interested parties. 
I do not recommend a change in the 100-year flood standard because it is an accepted standard 
by all levels of government. Instead, I would recommend the following: 
1. Map for the ultimate development of a community or jurisdiction. That is to show how the 
floodplain changes when development outside the floodplain occurs. Some states have 
required this for years. It is a tool for local governments to better guide the development of 
their communities. 
2. Change the program regulations on floodways to a zero rise. It was a major mistake to allow a 
one-foot rise when we wrote the regulations in 1974. 
3. In coastal areas enlarge the velocity zone to take into consideration the effect of erosion, the 
rise of the oceans, the protection of wetlands and mangrove swamps, and to look at what 
happens when a beach is eroded or washed out to sea. I hope the recently completed coastal 
erosion study provides the data to restrict new development in coastal areas. 
4. After a significant disaster, immediately re-map the floodplain using modern technology. This 
is important to prevent a replacement of an area that will be subject to future disasters.
Floodplain Management Forum 95 
5. I would like to see the flood insurance aspect of the program "red line the floodway and 
velocity zones for new and rebuilt construction. This means no new flood insurance would be 
sold in these areas thus discouraging unwise development. This may take an amendment to 
the Act, which could be difficult. However, it would serve the purpose of not rebuilding in a 
hazardous area and turning to the Federal Government for assistance again and again. FEMA 
has already started a similar program with its "repetitive loss" initiative. 
6. The program needs to become more environmentally sensitive to the effects the flood hazard 
maps have on the environment. 
Although this is not a problem of the National Flood Insurance Program, I would like to see 
FEMA and other Federal and State agencies to stop wasting taxpayer's dollars on beach 
nourishment programs. This policy only encourages unwise development in high hazard areas. 
The National Flood Insurance Program is one of the best programs in the Federal Government 
and to see changes that will make it an even more effective program will be a rewarding 
experience.
Floodplain Management Forum 96 
James Sadler, CPCU 
Vice President 
National Con-Serv, Inc. 
It is an honor and a pleasure to be here this afternoon. I thank Director Will for inviting me. It is 
always a special pleasure when I am able to talk about the NFIP, a Program that I have been 
dedicated to since 1983. My dedication to the Program is sustained because the NFIP must be 
among the most successful public/private partnerships ever seen in Washington and that it is 
doing truly good work while reducing the burden on the taxpayer. 
I add my concerns to others who have described the difficulties with terminology referring to 
one-hundred year and five-hundred year flooding events. It seems as if we have been discussing 
moving to alternate terminology for almost one hundred years. Perhaps now is the, time we can 
do something about an alternative. 
Fundamentally changing the NFIP must be approached very carefully. I feel that offering the 
participants of this Forum an opportunity to speak to the matter is evidence that the Director 
agrees that change must be considered very carefully before action is taken. 
The background paper for this Forum states the obvious. The mapping and remapping processes 
are antiquated and delayed because the funding has not been made available to de what those 
involved in flood hazard identification know must be done. It seems sensible to know where the 
hazard is and how it relates to flood insurance before fundamental changes to the transfer 
mechanism are made. 
However, some change may be helpful. Why do we purchase insurance? We purchase 
automobile liability insurance in many jurisdictions to maintain our driving privileges, or allow 
us to register and license our vehicles. We purchase life insurance because we either intuitively 
recognize the risk we expose our family to by not purchasing it or an effective life insurance 
sales person has explained this to us and we accept it. We may purchase insurance either 
because we are required to do so or because we recognize the risk associated with not doing so 
and make the responsible, personal decision to transfer the risk by purchasing insurance. 
We purchase hazard insurance on our real property because the mortgagee requires it or that we 
recognize that we could lose everything if we do not purchase the insurance. Perhaps we 
purchase hazard insurance because the process of making that purchase hits been 
institutionalized. 
The purchase is required for each real property loan. And yes, if it is not purchased before the 
closing, the mortgagee will not close the load, and if it is not kept in force the mortgagor will be 
reminded until a policy is purchased. 
On the other hand, the decision-making process involved in requiring flood insurance at closing 
and requiring coverage to be maintained is not institutionalized. When flood insurance is 
required and when it is not required may be confusing for many who make process decisions.
Floodplain Management Forum 97 
With each subsequent sale of a loan, which is accomplished with practically the speed of fight, 
the requirements become even more uncertain. 
Expanding the Mandatory Purchase Requirement to all zones within a participating community 
would certainly make the decisions easier and begin to institutionalize the processes. Again, to 
know the true offset of this expansion of the Mandatory Purchase Requirement, correctly 
identifying the hazard would be helpful. 
Premium or rate equity could be considered. Is it fair for a policyholder whose property has 
sustained several NFIP paid losses to pay the same premium as the policyholder whose property 
is otherwise identically rated, but has sustained no losses? Perhaps modest actuarially supported 
premium increases with each loss could be considered. The premium increases would be based 
non on fault, but on experience. The Repetitive Loss Properties Strategy is the first NFIP 
program to recognize the connection between multiple losses and increases in the amount a 
policyholder will have to pay for flood insurance. While the Repetitive Loss Properties law is 
not yet settled, any possible premium increase would take effect only after a policyholder refuses 
an offer of voluntary mitigation assistance. This experience rating approach would not violate 
the NFIP charter to provide previously unavailable flood insurance in flood-prone areas, but it 
would introduce premium equity to the NFIP. 
Again, it is an honor to be here. Thank you.
Floodplain Management Forum 98 
Frank Thomas 
Mitigation Consultant 
Placement of Fill in the Floodplain 
The NFIP condones placement of fill in the floodplain in two ways: (1) utilizing a Regulatory 
Floodway Standard that allows placement of fill until a one foot increase in base flood level is 
reached, a standard that increasingly being called inadequate, and, (2) granting Letters of Map 
Revision for placement of fill which recognize and approve placement of man-made fill in 
Special Flood Hazard Areas as a basis for exempting a parcel of land from flood insurance 
purchase and floodplain management requirements. The latter is bad public policy and should be 
terminated. Of the two, Letters of Map Revision are the most egregious, like a cancer eating at 
the foundation of the NFIF. 
The impact of fill placement on flood storage at a specific site in the floodplain varies depending 
upon fill type, size and location, and upon the flood hazard characteristics of the floodplain and 
its basin. Some placements may have immediate, visible negative impacts on flood water 
conveyance and ecological conditions on adjacent properties. The impact of other placements 
may be subtle and less evident. However each placement contributes to the cumulative impact of 
displaced storage on stream volume, velocity, and sediment conditions which in turn redefine 
flood hazard and impact floodplain natural resources. 
Consider the following adverse consequences of fill placement in the floodplain. 
A. Fill reallocates flood storage from the fill site to other locations in the floodplain thereby 
transferring the flood hazard and altering the risk for other floodplain properties. Significant 
cost burdens are inequitably imposed on other floodplain property owners and communities 
who, unaware, accrue the transferred flood risk without receiving protection from or 
compensation for the additional risk. This is especially true for Letters of Map Revision 
permitting fill for a large tracts of 10 or more land parcels. 
B. The accuracy of existing NFIP Special Flood Hazard Area map elevations is degraded on a 
site and cumulative basis. FEMA's fees for processing Letters of Map Revision requesting 
approval for placement of fill in the floodplain do not include adequate compensation to 
support the future updating of flood hazard maps necessitated in part by reallocation of flood 
storage. Moreover, FEMA commits large amounts of its limited technical personnel 
resources and half of its $50 million annual mapping budget to support, and monitor 
engineering consultants who process 3,000 Letters of Map Revision. Consequently, the 
number of new maps prepared has been significantly reduced and FEMA must continue to 
seek funding increases for the map program. 
C. The Flood Insurance Fund incurs a significant loss of premiums. Given an estimated annual 
policy premium of $350, in 1999 approval of 3,000 Letters of Map Revision each removing 
an estimated 5 land parcels from the floodplain resulted in over $5,000,000 of premium not 
collected. FEMA's fees for processing letters requesting placement of fill do not provide
Floodplain Management Forum 99 
adequate compensation for building insurance reserves to cover the risk reallocated to other 
insured properties. Moreover, property placed on fill has a residual flood risk, which may be 
shifted in part to disaster assistance programs. 
D. Placement of fill in the floodplain disrupts and often degrades natural and cultural resources 
associated with water supply quality and storage, wildlife habitat, ecological systems, and 
economic activities such as tourism. While difficult to measure, degradation of these 
functions can have major local and regional impacts. 
E. Enforcement of local government floodplain management regulations, largely required by 
the NFIP, is weakened by selective fill based exemptions which override 
local floodplain elevation and siting requirements. In so doing, exemptions discourage local 
enforcement and undermine the fundamental NFIP statutory responsibility to reduce flood 
risk and losses by guiding new development away from flood hazard areas. 
What Action Should be Taken? 
It is necessary and good policy to continue to use letters of map change to correct site data errors 
that occur in the technical processes of measuring and mapping the flood hazard. In such 
instances, the source of inaccuracy is FEMA which is legally bound to develop and maintain fair 
and equitable program standards. Letters of Map Revision allow placement of fill in the 
floodplain for purposes of land development do not intend to correct inaccuracies, Rather, they 
act to reduce accuracy. Reversal of current policy to permit Letters of Map Revision based on 
fill should be initiated immediately. 
Primary constituencies supporting fill are land developers, builders, and technical and 
engineering consultants retained to process map change letters. The consultants are least likely to 
be negatively affected by a policy change because their expertise would be needed to support an 
expanded program of updating and making new floodplain maps by redirection of funds now 
used to support letters of map change. On the side of terminating the fill policy is a less defined 
set of constituencies who are recently aware of flood hazard and insurance and are concerned 
about disaster and environmental costs. 
A policy change to terminate Letters of Map Revision for fill must assure all program 
constituents of fair and equitable treatment, and be pursued using full due process of rulemaking. 
A multi-year approach is needed, beginning in 2000 and concluding with final rule effective 
October 1, 2003. The process should include widespread public notice, and a period to inform 
and involve all constituencies in development of a proposed rule including a l2-18 month grand 
fathering period to allow land developers and builders to obtain Letters of Map Revision for 
projects in process. Limited grandfathering is essential to winning the political support for this 
major policy change.
Floodplain Management Forum 100 
Jerry Uhlmann 
Director, Missouri State Emergency Management Agency 
Flood Hazard Mitigation Identification 
1. Should the mapping of floodplains based on a higher standard, such as the 500-year 
standard? 
The 100-year standard, as it is currently determined and applied, does not provide true protection 
to the one percent flood event. Properly determined and applied, the one percent (100-year flood) 
standard for most development and redevelopment is appropriate. FEMA may consider requiring 
critical facilities be protected to the 0.2% event (500-year flood). 
2. How can the uncertainty in hydrology be addressed in the flood maps? 
No Response 
3. Should mapping be based on future conditions, accounting for urbanization and coastal 
erosion? 
Future conditions should be considered in the identification of flood prone areas, etc. How that is 
to be accommodated is not within our knowledge base. History, however, tells us that areas once 
considered as rural with little or no threat of flooding now are severely impacted by flash 
flooding. Rapid run off from heavy rains resulting in flash flooding has become the major flood 
threat in this state and accounts for nearly all of the flood related fatalities! Detailed watershed 
studies taking development into account is urgently needed. Unnumbered A zones must be 
eliminated and replace with proper documents! 
4. Does the current policy that recognizes levees or removes properties from the floodplain 
adequately reflect the flood risk? 
Current policy that recognizes levees and removes property from the special flood hazard area 
based on fill creates a false sense of protection. We know that many levees now "certified" at the 
100-year event are in fact marginal regarding protection. Once the Corps of Engineers flow 
frequency study results for the upper Mississippi and lower Missouri Rivers are released, many 
100-year levees will no longer provide such protection - the problem should be addressed at that 
time. The removal of areas due to fill (LOMR-F) in fact relieves developers from constraints 
and places them on individual home owners. This practice should cease without delay. 
5. Are hazards such as coastal erosion, alluvial fans, coastal flooding, high velocity flooding, 
and similar hazards adequately addressed in the hazard identification and mapping? 
No Response
Floodplain Management Forum 101 
6. Are current standards for designating floodways appropriate, particularly the allowance of 
a one-foot increase in flood stage? 
The one foot increase in flood stage should be eliminated from the process used to identify the 
regulatory floodway. 
7. Are there methods of identifying flood hazards other than the traditional mapping 
approach? 
We do not know of a quick or cheap method to accurately identify flood hazard areas. Mapping 
is the basic tool needed to administer this program. So long as developers believe they can 
challenge the validity of identified areas, many smaller less sophisticated governments are at a 
large disadvantage. Modem, accurate maps are essential - we support map modernization. In 
fact, we have communicated this position to every member of the U.S. Congress from this state! 
Floodplain Management 
1. Should a higher standard, such as the elevation to the 500-year flood, be implemented? 
The 100-year standard, as it is currently determined and applied, does not provide true protection 
to the one percent flood event. Properly determined and applied, the one percent (100-year flood) 
standard for most development and redevelopment is appropriate. FEMA may consider requiring 
critical facilities be protected to the 0.2% event (500-year flood). 
2. Should freeboard be required above the base flood? 
Due to the lack of accuracy of current of current flood maps and ever changing conditions, 
consideration should be given to modifying the National Flood Insurance Program requirements 
so that new construction has from one to three feet of freeboard above the current base flood 
elevation. This acknowledges any uncertainties and mapping errors. 
Most communities currently includes one foot above BFE in their NFIP ordinances - this should 
be mandatory given the inadequacies of maps. 
3. Are hazards such as coastal erosion, alluvial fans, coastal flooding, high velocity flooding, 
and similar hazards adequately addressed in the regulatory requirements? 
No response 
4. What strategies can be developed to encourage communities to adopt hazard mitigation 
plans or comprehensive plans and policies that steer development out of floodplains? 
A number of strategies could be considered to encourage communities to adopt hazard mitigation 
in order to steer unwise development from flood hazard areas and to encourage citizens to accept 
responsibility for their actions. The Community Rating System provides some incentive but not 
enough. Larger incentives are required to get the communities attention and to take action.
Floodplain Management Forum 102 
Incentives are usually fiscal. The most appropriate mechanism is the Disaster Relief cost-share or 
assistance. 
A. For individuals, federal assistance for flood losses should be based upon the individual's 
demonstrated willingness to mitigate the risk. Flood insurance is the best means of 
accomplishing this. Those living in identified flood hazard areas should not receive 
financial assistance if a flood insurance policy was not in place at the time of the flood. 
Additional mitigation grants should be made available to policyholders who take steps to 
mitigate their flood risk. The premiums on structures with repetitive losses and on those 
that are not primary residences should reflect the actual risk. 
B. For states and localities, programs for flood control structures, nonstructural flood 
measures, mitigation, and flood disaster assistance should all be based on the same, 
sliding cost-sharing formula for federal assistance. A minimum cost-share would be made 
available to all localities but the federal share would be increased for communities and 
state that engage in disaster-resistance activities exceeding minimum criteria and that are 
implementing strong mitigation programs. After a flood disaster, Public Assistance under 
the Stafford Act should be withheld from the damaged floodplain areas of communities 
not enrolled in (or not in compliance with) the National Flood Insurance Program. The 
"managing state" concept initiated by the Federal Emergency Management Agency 
should be used as an incentive to state involvement in and commitment to mitigation, and 
be expanded to other programs beyond the Hazard Mitigation Grant Program. 
C. All taxpayer-funded flood disaster relief should be contingent upon taking flood 
mitigation action. 
D. Much thought and evaluation is needed in these areas. The NFIP is a federal government 
program with voluntary arrangements with local governments. States must play an ever 
increasing role in the NFIP if the program is to meet expectations currently as well as far 
the future. This arrangement allows the collective state governments and their 
considerable resources to assume the role of "spectator" in the NFIP. Incentives must be 
put in place to cause the states to participate actively in the program. Perhaps the only 
means to bring this about is through a fiscal impact. The federal share related to flood 
assistance could be based on demonstrated NFIP support on the part of a state. 
5. Are there other things the Program can do to increase levels of protection for flood-prone 
properties? 
Other things the NFIP can do to increase levels of protection are flood maps depicting failure 
zones of dams, levee and floodwalls, new flood structural measures should be built to the 2% 
(500-year) chance flood and not to one percent (100-year) chance flood. 
In all, too many communities within this country, trailer parks are found in or very near the 
special flood hazard areas. Many of these parks existed pre-FIRM and elevation requirements, 
etc. do not apply. In many parks, the trailers are also owned by the landlord with renters 
occupying the trailer. The NFIP should include a provision that requires mobile home parks to be
Floodplain Management Forum 103 
posted with clear notice to occupants that a particular park is located within the special flood 
hazard arm. 
6. What strategies and incentives can help encourage states and communities to foster 
sustainable development and discourage inappropriate floodplain development. 
For those communities that have joined the NFIP - the ordinances that they are required to adopt 
– if property enforced cause any new or substantially damaged property to meet elevation 
requirements. Unfortunately, much of what is found in special flood hazard areas was present 
pre-FIRM! This program, the NFIP is really only about 30 years old and not a very long time 
when the history of communities is considered. For many states with a long history of 
development along the banks of major rivers, these pre-FIRM properties will be with us for 
many more decades. Consideration should be given to the following new policy or incentives: 
A. All NFIP participating communities should be required to develop and adopt 
comprehensive flood mitigation plans. 
B. SBA disaster assistance loans are not available to residents of non participating 
communities - public assistance - public assistance should not be available to non 
participant or sanction communities. 
C. The National Flood Insurance program needs to go to more of an actuarial rate for 
policies on repeatedly flooded structures and pre-FIRM structures. 
The local and state officials responsibilities and capabilities need to be clarified and 
strengthened. People should not expect to be bailed out by the federal government after every 
flood event. 
A. Public Assistance should be withheld from the damaged floodplain areas of communities 
not enrolled in (or not in compliance with) the National Flood Insurance Program. Today 
there are few, if any, economic sanctions for local governments that fail to participate in 
the National Flood Insurance Program, even though their failure makes their citizens 
ineligible for Individual Assistance, federal home loans, and other services. In effect, the 
individual citizens are penalized, while the municipality continues to get bailed out. 
B. Federal financial assistance for flood losses should be based upon the individual’s 
demonstrated willingness to mitigate the risk. Flood insurance is the best means of 
accomplishing this. Those living in flood hazard areas should not receive disaster 
assistance if a flood insurance policy was not in place at the time of the flood. Additional 
mitigation grants should be made available to holders of flood insurance policies on 
primary residences and commercial structures who take steps to mitigate their flood risk. 
The premiums on structures with repetitive losses and on those that are not primary 
residences should reflect the actual risk. 
C. The non-federal share of disaster assistance costs should be reduced in communities 
where state and local efforts are mitigating the flood hazard.
Floodplain Management Forum 104 
D. Federal assistance for individuals should be based upon whether they had a flood 
insurance policy before the disaster, even if their property lies outside of the one percent 
chance floodplain. The total amount of assistance received by an individual should be 
reduced (or a portion of it converted to loans) to reflect the amount of damage that could 
have been covered by a flood insurance policy. 
E. The Community Assistance Program needs to be revisited because, although it has 
provided products for the Federal Emergency Management Agency, it has tended to 
replace state capabilities rather than encourage states to develop more of their own 
capacity. 
7. What can be done to instill a greater sense of responsibility for states, communities, and 
citizens for inappropriate floodplain development that puts people and property at risk? 
Normally the incentives that will get the attention of communities and states to encourage 
sustainable development and discourage inappropriate floodplain development is money. The 
non-federal share of disaster assistance cost should be reduced in communities where state and 
local officials have a successful mitigation program. FEMA's Project Impact which developed 
model "disaster-resistant" communities through public-private partnerships, citizen involvement, 
planning and multi-hazard and multi-purpose approach to mitigation should be expanded and 
encouraged. 
8. What strategies can be developed to address the flood risk to structures constructed prior to 
the NFIP? 
The National Flood Insurance Program needs to go to more of an actuarial rate for policies on 
repeatedly flooded structures and pre-FIRM structures. 
Insurance 
1. Should the mandatory flood insurance purchase requirement be extended to apply outside of 
the 100-year floodplain? Are there other ways to increase coverage in these areas? 
Flood insurance requirements should apply outside the 100-year floodplain when disaster or 
insurance claims are made. 
2. Are there methods to improve implementation of the mandatory purchase requirement by 
federal agencies and lenders? 
We believe, due to inquiries that we receive, lenders are enforcing mandatory purchase 
requirement adequately. 
3. Are there ways to ensure that once purchased, flood insurance policies remain in place? 
This issue can be improved in a number of ways:
Floodplain Management Forum 105 
A. First of all, change the database to track properties by parcel ID numbers instead of 
names and addresses 
B. Create incentives on the part of agents such that they place as much emphasis on flood 
insurance and policy renewals as they do for other lines of insurance. 
C. Flood insurance should be mandatory to receive disaster benefits. 
4. Are there ways to increase insurance coverage to buildings not subject to the mandatory 
purchase requirement? 
Flood insurance should be required as a prerequisite to receive any type of disaster assistance. 
5. Should flood insurance be required behind levees? 
Properties in protected areas behind levees should be subject to the same mandatory lender 
requirements with the rates based on residual risk. 
6. Is the current flood insurance rating model sufficient, or are there other methods to rate the 
flood risk? 
No Response
Floodplain Management Forum 106 
David R. Conrad 
Water Resources Specialist 
National Wildlife Federation 
On behalf of the National Wildlife Federation, the nation's largest conservation education 
organization with over 4 million members and supporters and affiliate conservation 
organizations in 46 states and territories, I greatly appreciate the opportunity to participate in 
FEMA's Floodplain Management Forum. Improving the nation's floodplain management has 
been a longstanding interest and high priority of the Federation and many of the nation's 
conservation organizations. 
We are most pleased that FEMA and Director Witt have established this Forum to address the 
NFIP and the nation's approach to floodplain management. 
For much of the past century, the federal government has approached the problem of flooding 
largely through structural- means - building dams, levees, floodwalls, channelizations, jetties and 
using other means to modify the natural flow fluctuations of rivers, streams, and coastlines. 
Conservationists have had major, ongoing concerns about the environmental damage that has 
been brought on by many structural projects. Many of these projects have resulted in significant 
habitat losses and major declines in water-dependent species. In addition, this approach has been 
extremely costly. 
For instance, in current dollars the Army Corps of Engineers has spent over $100 billion on flood 
control projects - mostly since the late 1940's. Other federal agencies and local public works 
agencies have spent untold billions more. We find that while many of these projects have 
prevented significant flood damages, they have also created a false sense of security. Many 
communities have continued to build in floodplains only to experience catastrophic losses when 
large floods come. During the 20th century, we have witnessed an alarming rise in national flood 
damages that has grown from approximately $2 billion annually (current dollars) early in the 
century to an all time high of $5 to $8 billion annually during the 1990's, according to National 
Weather Service records. 
We applaud FEMA's new emphasis on hazard mitigation and its substantial success in 
supporting voluntary buyouts of floodprone properties. This has begun to reverse past trends of a 
repeated flood-pay-flood-pay cycle identified in a National Wildlife Federation study in 1998 
called Higher Ground. To date the HMGP program has supported some 21,000 voluntary 
property buyouts, mostly since the 1993 Midwest Flood. 
The heavy emphasis on structural flood control, even when combined with the land use and 
building controls of the current NFIP, have not adequately turned the tide on flood damages. 
Changes in the nation's approach to managing flood risks and protecting floodplain functions and 
related natural resources are clearly needed. We must recognize that with wise management, 
floodplains can provide valuable natural and cultural services and functions to our communities, 
and we should explore ways to manage these areas more often as open spaces that can serve 
communities without being subject to high risk to lives and property.
Floodplain Management Forum 107 
FEMA is in a unique position to help provide new direction to make such changes. We would 
suggest the following-. 
Flood Hazard Identification 
From the beginning of the NFIP, it was recognized that the 100-year standard was a 
“ compromise.” The standard was intended to represent a minimum that communities would be 
encouraged to exceed. Yet unfortunately, many communities have viewed this standard as the 
"maximum." Due to the manner in which the standard has often been applied, much new 
development and building reconstruction has proceeded with structures that are at much greater 
risk than was intended by the 100-year standard. 
FEMA should encourage all communities to identify and manage development, particularly 
critical infrastructure and facilities, to be located outside 500-year (2% chance) flood areas. We 
would urge FEMA to consider raising the NFIP program standard generally to a higher level 
than the 100-year level, perhaps the 500-year flood level, where practicable. 
In the interim, we would recommend that FEMA take the following steps to better implement the 
present 100-year standard: 
· Establish a no-rise, no-impact floodway instead of the current one-foot rise floodway. This 
should include a requirement of no or de minimus impact on surface elevation or velocity. A 
number of states have already taken important steps in this direction. 
· Move forward rapidly on the flood map modernization initiative. Outdated and 
inaccurate maps undermine every aspect of the NFIP and floodplain management. 
Base flood maps on future condition hydrology. 
· Identify all flood-related hazards on flood maps, including dam and levee failure zones, 
shoreline erosion zones, high-velocity flooding and alluvial fan areas. 
· Apply the mandatory flood insurance purchase requirement to areas in natural floodplains 
below dams and behind levees to provide coverage for residual risks associated with failure 
of structural flood control projects. 
Floodplain Management and Insurance 
Fundamentally, the federal government has assumed too much of the total responsibility for 
flooding problems. Federal policies should be adjusted to foster much greater sharing of 
responsibility with state and local governments and individuals. Many elements of floodplain 
policy promote rather than discourage building in floodplains, and as a result fail to protect the 
natural services provided by these special areas. In the NFIP, built-in subsidies and crosssubsidies 
have sent the wrong economic signals, have failed to discourage high-risk 
development, and have left the program in a chronic, financially precarious state. We would 
recommend the following:
Floodplain Management Forum 108 
· Make a concerted effort to set flood insurance rates on an actuarially-sound basis. Eliminate 
cross-subsidies within zones, phase out pre-FIRM subsidies, phase out grandfathering when 
maps are revised and subsidies for non-primary residences, incorporate erosion risk into ratesetting, 
adjust future rates to actuarial levels when substantial damage or substantial 
improvement occurs, plan for catastrophic loss contingencies. 
· Require a 1-3 foot freeboard for new construction above the current base flood 
elevation. This would help to account for the significant risk and uncertainty associated with 
flood height prediction. 
· Educate and encourage communities to protect the natural and beneficial functions of 
floodplains. Many communities have begun to affirmatively plan their floodplains for 
multiple objective management, such as greenways and open space, parks and recreation, 
fish and wildlife refuges, wetlands, trails and bikeways, agricultural areas, and vegetated 
buffers to protect water quality. Such uses are key tools in addressing problems of urban 
sprawl. 
· Support a substantial initiative to address repetitive losses. The National Wildlife Federation 
strongly supports H.R. 2728, the "Two Floods and You Are Out of the Taxpayers Pocket 
Act" to provide additional funds for hazard mitigation of repetitive loss properties. 
· Begin to incorporate measures identified in the Community Rating System as standard 
requirements for community NFIP participation. For the past two decades, community 
participation requirements have remained essentially static. The CRS identifies the best 
floodplain management practices, and provides a strong basis for improving standards 
generally. 
· Require setbacks for new construction in coastal erosion areas, set rates on a true actuarial 
basis, and require regulation of erosion hazards. Coverage should be denied in highest risk 
locations. 
· Halt issuance of Letters of Map Revision for placing fill in floodplains and for river 
channelizations to circumvent the NFIP mandatory purchase and land use and building code 
requirements. 
· Improve coordination between FEMA Disaster Assistance programs and the NFIP. Other 
Programs and Policies 
Other Programs and Policies 
Overall, the National Wildlife Federation urges FEMA to take the lead in bringing together all of 
the federal agencies and departments with interest in floodplain management to formulate a more 
consistent and comprehensive strategy to encourage wise management of floodplains. The efforts 
thus far by FEMA and Director Witt to alert the public to the importance of taking much more 
responsibility for floodplain management has been and continues to be invaluable to the nation.
Floodplain Management Forum 109 
While it is impossible to list all relevant programs here, we recommend in particular two 
immediate priorities: 
· Revitalize the Interagency Task Force on Floodplain Management. This body could serve as 
a coordinating entity for developing comprehensive strategies and improved federal policies. 
· Issue a Revised Floodplain Management Executive Order. This was a key recommendation 
of the Galloway report, and could make a significant contribution to bringing federal 
agencies together in improving floodplain policies. 
Attached are additional items reflecting Federation priorities regarding floodplain management 
and the NFIP. 
Once again, we appreciate the opportunity to participate in the FENM Floodplain Management 
Forum, and look forward to a productive discussion. 
Floodplain Management 
· FEMA must amend policies and programs to discourage future growth and development of 
floodprone areas, and continue to emphasize non-structural approaches to flood control over 
structural measures. 
· Tie disaster relief and other Federal funds to participation and compliance in the National 
Flood Insurance, Program (NFIP). 
· FEMA should take the lead to establish a task force with other Federal agencies to 
coordinate, flood plain policies among a range of Federal programs. 
· Require local hazard mitigation plans to be tied into overall comprehensive master plans. 
· Educate and encourage communities to protect and manage floodplain areas for open space 
and recreation. 
· Increase community awareness about flood risk. Describe 100-year floodplain as areas of " 
high flood risk", and areas within the 500-year floodplain as "moderate flood risk". 
Insurance 
· Revise flood insurance rates to be, realistic and account for repetitive losses. 
· Require rates to accurately reflect risk to individual properties by proximity to the 
hazard and by the class of structure. 
· Establish new and concise standards for determining the substantial damage/substantial 
improvement rule. New standards should calculate damage over time, and use the fair market 
value over the replacement value of the structure.
Floodplain Management Forum 110 
· Adopt a policy of a "no-rise floodway" with a requirement of no impact on water surface and 
velocity for new construction. 
· Require a minimum of at least one to three feet of freeboard for structures located in the 100- 
year floodplain. 
· Stop the abuse of Letters of Map Amendment (LOMAs). Areas with LOMAs should not be 
exempt from flood insurance. The NFIP should maintain its mandatory purchase requirement 
in areas with, natural flood hazards, regardless of the additional fill and stream 
channelization. Instead, base insurance rates for these areas on residual risk. 
· Deny NFIP coverage for new structures seaward of the 30-60 year erosion zones, depending 
on the type of construction and portability of structures, regulate erosion hazard, and require 
true actuarial rates that reflect the erosion factor. 
· Require mortgage companies to provide notification of mandatory NFIP purchase 
requirements when lending to repetitive loss properties. 
Flood Hazard Identification 
· Ensure the accuracy and availability of NFIP claims data, as well as the location and number 
on the overall number of flood-prone structures across the Nation. 
· Base Flood Insurance Rate Maps (FIRMS) on projected, not current, conditions of 
development (with the exception of areas where no increase in post-development runoff is 
permitted). 
· Reevaluate all areas with aging structural flood control measures for risk and capacity, and 
update FIRMs accordingly. Require insurance for residual risk. 
· FIRMS should be expanded to identify the 500-year floodplain, and all hazards, including 
coastal erosion, high velocity floods, and alluvial fans, and indicate failure zones for 
structural measures. 
Other Programs and Policies 
· Support legislation to create major acquisition and relocation programs for repetitive loss 
properties. 
· Amend E.O. 11988 to go further in promoting non-structural floodplain management and the 
restoration of the natural and beneficial functions of floodplains. 
· Recognize the economic benefit of natural and cultural resources in Benefit Cost Analysis.
Floodplain Management Forum 111 
Floodplain Natural and Beneficial Functions 
and 
Flood Loss Reduction 
Jon Kusler 
Executive Director, 
Association of State Wetland Managers 
How can FEMA and other agencies better reduce flood losses while, simultaneously, protecting 
floodplain natural and beneficial functions? 
I'd like to share some summary thoughts on three topics based upon my experience over the last 
three decades with flood loss reduction and floodplain management, wetland protection and 
restoration, stream protection and restoration, and broader watershed and land management 
programs: “Why will protection and restoration of floodplain natural and beneficial functions 
reduce flood losses? Why do existing flood loss reduction efforts fail to protect natural and 
beneficial functions? What measures could FEMA, other federal agencies, states and local 
governments take to simultaneously better reduce flood losses and protection floodplain natural 
and beneficial functions? 
Why will protection and restoration of floodplain natural and beneficial functions reduce 
flood losses? 
Efforts to protect floodplain natural and beneficial functions can also reduce flood, erosion, and 
wind (hurricanes) losses for three principal reasons. 
1. Efforts to protect and restore floodplain natural and beneficial functions can keep flood 
loss prone activities out of the floodplains and relocate these activities to safer areas. 
Multi-objective programs to protect and restore natural and beneficial functions by limiting and 
removing floodplain and floodway development can also reduce flood, erosion, and wind losses 
(hurricane). These include local, state, and federal greenway development, park acquisition, 
wetland regulation, wetland restoration, stream restoration, and other floodplain resource 
protection and restoration programs. Such efforts can not only reduce losses for residential, 
commercial, and industrial development in hazard prone areas but also reduce flood-related 
damage to roads, sewers, water supply systems, and other infrastructure which serve such 
development. 
2. Multi-objective efforts can increase the political support for flood loss reduction measures. 
Multi-objective floodplain management programs such as Tulsa's program can increase the 
political support for flood loss reduction by providing benefits such as recreation, water quality 
protection, bird watching, and ecotourism. Local citizens may be motivated to implement multi-
Floodplain Management Forum 112 
objective efforts in the predisaster planning context rather than reacting after disasters when the 
damage has occurred and public concern for flood losses is high. 
3. Multi-objective efforts can increase the funding support for flood loss reduction measures. 
Multi-objective efforts can tap grants, bond issues, and other sources of funding for water quality 
protection and restoration, recreation, wildlife, and endangered species as well as flood loss 
reduction. 
Why do existing flood loss reduction fail to protect natural and beneficial functions? 
Existing flood loss reduction efforts including the construction of flood control structures, 
drainage, channelization, and some types of flood plain regulation fail to protect natural and 
beneficial functions for a variety of reasons: 
1. Floodplain managers often fail to consider natural and beneficial functions because of lack of 
explicit natural and beneficial function protection and restoration goals in flood loss reduction 
programs. 
2. Flood loss reduction and natural and beneficial function programs have been established by 
separate enabling statutes and have separate funding and staffs which discourages integration 
and cooperation. 
3. Floodplain managers attend floodplain conferences, read floodplain newsletters, and 
communicate with other floodplain managers; wetland, water quality, wildlife, and other 
managers with responsibilities related to natural function and values do the same with little 
exchange of information across professions. 
4. Most structural approaches to flood loss reduction have severe impacts on natural and 
beneficial functions. 
5. Model flood loss reduction ordinances and rules allow (and in some instances encourage) 
development in wetlands and other flood fringe areas. 
6. Flood regulatory and disaster assistance subsidies often favor development or redevelopment 
without consideration of natural and beneficial functions. 
7. Many local governments and landowners continue to be only familiar with the concept of an 
“engineered” flood loss reduction project with structures and concrete rather than multiobjective 
greenway or other approaches to both reduce flood losses and protect and restore 
natural and beneficial functions. 
8. Inadequate dissemination of information and training has taken place for flood loss reduction 
personnel with regard to protection of natural and beneficial functions; the same problem 
occurs with wetland, stream management, and other resource management personnel with 
regard to flood hazards and flood plain management.
Floodplain Management Forum 113 
What measures could FEMA, other federal agencies, states and local governments take to better 
reduce flood losses and protection floodplain natural and beneficial functions? 
Some priority measures include: 
1. Federal agencies, Congress, state agencies and legislatures, and local governments should 
include explicit protection and restoration of natural and beneficial function goals in flood 
loss reduction statutes, regulations, and ordinances. A no net loss of function goal should be 
adopted. Many floodplain managers will continue to overlook or ignore natural and 
beneficial functions without adoption of such goals. 
2. Federal agencies and the Administration should adopt a strengthened floodplain management 
executive order. This Order should more clearly recognize natural and beneficial functions 
and discourage further development in the floodplain. 
3. FEMA should aggressively promote and reflect the benefits of protecting natural and 
beneficial functions in FEMA's Community Rating System and Project Impact Program 
through additional guidance and strengthened incentives. 
4. FEMA, the Corps, USGS, NRCS, EPA, NOAA, Fish and Wildlife Service and other federal 
and state agencies should encourage professional organizations representing flood loss 
reduction experts and managers and wetland/stream experts and managers to jointly 
distribute information concerning flood loss reduction and protection/restoration of natural 
and beneficial functions including wetland/stream restoration as part of outreach and training 
sessions including conferences, workshops, symposia. 
5. FEMA, the Corps, EPA, USGS, NRCS, NOAA, Fish and Wildlife Service and other federal 
and state agencies should provide training and information concerning natural and beneficial 
functions to flood loss reduction staff. They should also, conversely provide training and 
information concerning floods and other natural hazards to wetland regulatory, wetland 
restoration, stream restoration, and other personnel. 
6. FEMA, other federal agencies, and states should modify model flood loss reduction 
ordinances to recognize the importance of natural and beneficial functions and provide a zero 
rise goal for floodplains. 
7. FEMA, the Corps, EPA, USGS, NRCS, NOAA, Fish and Wildlife Service and other federal, 
state, and local agencies should continue to support relocation of repetitively damaged 
structures. Protection and restoration of natural and beneficial functions should be made 
more explicit goals of such relocation and restoration programs. 
8. FEMA, the Corps, EPA, USGS, NRCS, NOAA, Fish and Wildlife Service and other federal, 
state, and local agencies should more actively encourage communities to prepare disaster
Floodplain Management Forum 114 
mitigation plans which protect and restore natural and beneficial functions in both pre and 
post flood planning contexts. 
9. FEMA, the Corps, EPA, USGS, NRCS, NOAA, Fish and Wildlife Service and other federal, 
state, and local agencies should reflect geologic as well as hydraulic and hydrologic 
parameters in floodplain mapping. They should also assess and map or otherwise designate 
floodplain areas serving particularly important natural and beneficial functions such as 
wetlands, rare and endangered species habitat, flood storage, erosion control, pollution 
control, fisheries, and recreation.
Floodplain Management Forum 115 
Evaluation of Erosion Hazards 
Summary 
William Merrell 
President, The Heinz Center 
Driven by a rising sea level, large storms, flooding, and powerful ocean waves, erosion wears 
away the beaches and bluffs along the U.S. ocean and Great Lake shorelines. Erosion 
undermines waterfront houses, businesses, and public facilities, eventually moving the shoreline 
inland, erosion also brings nearby structure ever closer to the water, often putting them at greater 
risk than either their owners or insurers recognize. 
Over the next 60 years, erosion may claim one out of four houses within 500 feet of the U.S. 
shoreline. To the homeowners living within this narrow strip, the risk posed by erosion is 
comparable to the risk from flooding, especially in beach areas. The National Flood Insurance 
Program (NFIP), however, does not map erosion hazard areas to inform homeowners of the risk 
they face, nor does it directly incorporate erosion risks into its insurance ratemaking procedures. 
Both of these shortcomings can be remedied. 
Congress debated erosion management legislation during the early 1990’s, but could not reach 
agreement on a course of action. Depending that more information was needed, Congress passed 
Section 57 of the National Flood Insurance Reform Act of 1994 (P.L. 103-325), which requested 
an analysis of a series of possible policy changes to address erosion hazards within federal 
programs. 
This report, by The H. John Heinz III Center for Science, Economics and the Environment, is a 
response to that mandate. The goal of the study is to improve understanding of he impacts of 
erosion and erosion-related flooding on the NFIP, other federal programs, and coastal 
communities. The report makes two recommendations, shown in Box A
Floodplain Management Forum 116 
Box A. Recommendations 
Congress should instruct the Federal Emergency Management agency to develop erosion 
hazard maps that display the location and extent of coastal areas subject to erosion. The 
erosion maps should be made widely available in both print and electronic formats. 
Flood Insurance rate maps do not inform current and prospective coastal property owners of 
erosion risks. Without such information, state and local decision makers and the general public 
are not fully aware of the coastal hazards they face, nor do they have this information available 
for land-use planning and erosion hazard mitigation. This expenditure is likely to be cost 
effective. 
Congress should require the Federal Emergency Management Agency to include the cost of 
expected erosion losses when setting flood insurance rates along the coast. 
Despite facing higher risk, homeowners in erosion-prone areas currently are paying the same 
amount for flood insurance as are policyholders in non-eroding areas. FEMA should incorporate 
the risk from erosion into the cost of insurance along the coasts. Otherwise, other NFIP 
policyholders or taxpayers will have to subsidize what is likely to become a substantial cost. 
Using maps such as those recommended above, rate increases could be confined to the highestrisk 
eroding regions. Alternatively, more modest rate increases could be spread across a larger 
“Coastal High Hazard Zone” that includes both the highest-risk flood and eroding regions. 
The complete “Evaluation of Erosion Study” report is available at www.heinzcenter.org.
Floodplain Management Forum 117 
Remarks by Jo Ann Howard 
Federal Insurance Administrator 
Thank you for that introduction. Director Witt and Associate Director Armstrong, I know I 
speak for many people at this forum -- and across this country -- when I thank you for the 
exceptional leadership you have displayed in changing the way Americans think about disasters. 
It is my particular honor to recognize the presence at this conference of Dr. Gilbert White. He is 
one of the select few figures of the 20th Century whose careers will be understood by historians 
to have fundamentally reshaped -- and renewed -- life in the United States. 
I am also here to talk about a fundamental reshaping -- and renewal -- one of our national ideas 
about floods. As it does today, the last fundamental reassessment of flood management occurred 
at the dawn of a new century. One hundred years ago, the solution was structural. Floods were 
managed by erecting dams. The policy was one of high stakes and hard choices. When dams 
broke, bottled-up waters raged -- and routed -- even more fiercely. Even when dams held, their 
operators faced the wrenching calculus of sinking some communities for the sake of saving 
others. Meanwhile, this structural approach has, for too long, pitted protection of the 
environment against protection of our people when we know the two must work hand in hand. 
If flood policy at the dawn of the last century was one of terrible choices, our approach at the 
dawn of this new millennium can be one of terrific choices. In his lecture last year, Gilbert 
White -- who more than anyone else has lived the last century of water policy -- called for 
moving our focus from loss prevention to the beneficial uses of the flood plain. By taking a 
holistic view of flood plain management -- focusing not just on the reduction of loss, but the 
renewal of land and the stewardship of resources -- we can craft a policy whose payoffs are 
protection and possibilities alike. 
Flood policy has typically been the province of emergency managers. But it is not a discrete 
field. Decisions made in areas ranging from transportation to the environment to economic 
development have a substantial impact on the flood plains -- and flood plain decisions, in turn, 
have a substantial influence on these spheres of policy. Neither flood plains nor flood waters 
respect the territorial boundaries that divide government agencies or academic disciplines. Each 
of these areas -- and more, from preserving habitats to protecting homes -- must work in tandem. 
They must work in tandem first and foremost because a holistic view of flood plain management 
-- one focused on the beneficial use of the flood plain -- is our best tool for protection. But it is, 
in equal measure, our most effective agent for possibilities. 
The beneficial use of flood plains means preserving the open space that makes communities 
more beautiful. It provokes effective zoning and planning that makes neighborhoods more 
livable. It triggers creative thinking about the flood plain -- like grasses that absorb flood waters 
and generate biofuels -- creative thinking that both saves money and creates wealth.
Floodplain Management Forum 118 
The seeds of this new approach to flood policy were planted in 1968 with the creation of the 
National Flood Insurance Program. Its mission was to reduce the cost of floods to taxpayers. 
Measured against that goal, NFIP has been an unqualified success. We are saving taxpayers an 
estimated $1 billion a year in flood costs. The program has reduced flood damages to individual 
buildings by 77 percent. Perhaps more compelling than those hard metrics is this hard fact: By 
creating an incentive to reduce flood losses, the NFIP has woven disaster resistance into the 
fabric of community decisions. 
Today, insurance -- which remains a powerful financial incentive -- is still the natural launching 
pad for a new approach to flood plain management. 
Why do we need a new approach? For several reasons. The number and severity of catastrophic 
weather events is climbing. Riverine flood damage now exceeds $5 billion a year. Thoughtful 
people have asked whether the availability of insurance is providing comfort -- and, therefore, a 
catalyst -- for building in harm’s way. 
We are interested in all these questions. But most important, we believe self-evaluation is far 
more important than self-congratulation. 
That’s why we have undertaken a comprehensive evaluation of our program and its impact on 
floodplain management in the United States. Rarely in government do we have the luxury of 
looking over the mountaintop and not at the pebbles beneath our feet. We are doing that through 
this review. We have issued a nationwide call for information, ideas and input in six basic areas. 
First, what is the state of occupancy and use of flood plains -- and how is the NFIP affecting both 
issues? 
Second, what are the costs and consequences of flooding -- measured not just in economic terms, 
but in environmental and social ones as well? 
Third, how effectively do our insurance rating and indemnity functions operate? We are 
interested in whether the policies we offer support our goal of flood plain management, how we 
can risk rate NFIP policies more simply, and more. 
Fourth, how has the NFIP influenced local decisions on floodplain management? The premise of 
the program is an exchange of federal benefits for local controls. We want to know whether and 
how that quid pro quo is working. 
Fifth, we are reviewing our systems for hazard identification and risk assessment. This includes 
the accuracy of flood maps and other risk information, how they are used and whether more 
detailed maps could be financed. 
Finally, how effectively does NFIP communicate with the public? 
By the time of the Natural Hazards Center meeting in Boulder, we hope to have let a contract to 
develop the methodologies and approaches to explore these questions. This will be followed by
Floodplain Management Forum 119 
a separate effort to address the various questions, utilizing the expertise of independent experts, 
under an overall coordinating mechanism. I look forward to hearing your ideas today as well. 
And in addition to your input, I also ask for your patience. In insurance more than any other 
field, the basis of good ideas is good information. And if we want good information, we need 
time. Compiling the data alone could take two years. The entire evaluation process could take 
as many as five. 
I close with this thought: Wherever you believe the perfect approach for our floodplains lies, the 
practical approach will not be found in the extremes. We cannot afford for this opportunity to be 
stifled by extreme opponents of development or extreme opponents of environmental protection. 
The best policy will come from the facts, not the fringes. 
Here are a few facts to start with. First, as a matter of simple arithmetic, there will be new 
development. Our population is growing and our land is not. Second, we are not going to move 
Americans away from water -- nor will we simply dictate by policy fiat how they use their land. 
Ownership of land -- and an affinity for the water -- are bound up in the American way of life as 
intricately as water is bound up in life itself. 
But the following facts are equally compelling: If we build wholesale in floodplains, property 
will be destroyed, people will be hurt and the price tag will be enormous. If we degrade the 
environment, we will bring about more weather events and erode our natural protection against 
those that occur. 
Lastly, whatever approach we take to flood plain management must be a partnership between all 
levels of government and the private sector. Washington cannot dictate local land use decisions 
and, in my view, it should not try. Some of the most innovative ideas in flood plain management 
are being generated at the state and local level. At the national level, we need to lead, but we 
also need to listen. 
By leading our country and listening to our constituents, we can complete the cycle of history 
that began, a century ago, with the last reassessment of flood policy. That policy was one of 
terrible choices. Together, we can replace those terrible choices with terrific ones. By focusing 
on the beneficial use of the flood plain, we can reduce losses -- but also renew land. A holistic 
approach to managing our flood plains can be a tool of protection -- and, in equal measure, an 
agent of possibilities. I look forward to hearing your ideas on how to reach both goals. 
Thank you.
Appendix A 
Participant List
FEDERAL EMERGENCY MANAGEMENT AGENCY 
Floodplain Management Forum 
The Madison Hotel 
Washington, DC 
June 8, 2000 
PARTICIPANT LIST 
George Bernstein 
Partner 
Bernstein Law Firm 
Suite 313 
1730 K Street, NW 
Washington, DC 20006 
(202) 452-8010 
(202) 296-2065 FAX 
gkblaw@aol.com 
James F. Berry 
American Planning Association 
Representative 
Department of Biology 
Elmhurst College 
Elmhurst, IL 60126 
(630) 617-3581 
(630) 617-3735 FAX 
jimb@elmhurst.edu 
Grady P. Bray 
Chief Executive Officer 
Bray Associates 
131 East Lake Road 
Penn Yan, NY 14527 
(315) 536-0849 
(315) 536-0875 FAX 
gradybray@aol.com 
Michael Buchert 
Assistant Public Works Director 
City of Tulsa 
Room 512 
200 Civic Center 
Tulsa, OK 74103 
(918) 596-7274 
(918) 596-7397 FAX 
mbuchert@ci.tulsa.ok.us 
Sue Cameron 
County Commissioner 
Tillamook County Commission 
201 Laurel Avenue 
Tillamook, OR 97141-2311 
(503) 842-3403 
(503) 842-1384 FAX 
scameron@co.tillamook.or.us 
W. Dave Canaan 
Director 
Mecklenburg County Storm Water Services 
700 North Tryon Street 
Charlotte, NC 28202 
(704) 336-3736 
(704) 336-3846 FAX 
canaawd@co.mecklenburg.nc.us
2 
David R. Conrad 
Water Resources Specialist 
National Wildlife Federation 
1400 16th Street, NW 
Washington, DC 20036 
(202) 797-6697 
(202) 797-5486 FAX 
conrad@nwf.org 
Ed Copeland 
Certified Floodplain Manager 
Region II 
Planning and Development Council 
1221 Sixth Avenue 
Huntington, WV 25701 
(304) 529-3357 
(304) 529-7229 FAX 
ecopeland@citynet.net 
Michael Davis 
Deputy Assistant Secretary of the 
Army Civil Works 
U.S. Army 
Room 2E 569 
108 Army Pentagon 
Washington, DC 20310-0108 
(703) 695-1370 
(703) 697-3366 FAX 
michael.davis@hqda.army.mil 
Michael Ellegood 
Chief Engineer and General Manager 
Flood Control District of Maricopa County 
2801 West Durango Street 
Phoenix, AZ 85009 
(602) 506-4700 
(602) 506-4601 FAX 
mse@mail.maricopa.gov 
Kenneth Ford 
Manager for Civil Engineering 
National Association of Homebuilders 
1201 15th Street, NW 
Washington, DC 20005-2800 
(202) 822-0228 
(202) 822-0369 FAX 
kford@nahb.com 
W. Craig Fugate 
Bureau Chief of Preparedness and Response 
Department of Community Affairs 
Florida Division of Emergency Management 
2555 Shumard Oak Boulevard 
Tallahassee, FL 32399-2100 
(850) 413-9837 
(850) 488-1016 FAX 
craig.fugate@dca.state.fl.us 
Kathryn Hohmann 
Director 
Environmental Quality Program 
Sierra Club 
404 C Street, NE 
Washington, DC 20002 
(202) 547-1141, ext. 7916 
(202) 547-6009 FAX 
kathryn.hohmann@sierraclub.org 
M. Rita Hollada , CPCU, CIC, CPIA 
Chairman 
Flood Insurance Producers National 
Committee 
The Insurance Professionals 
P.O. Box 1000 
Selbyville, DE 19975 
(302) 436-9339 
(302) 436-9339 FAX 
Larrynrita@compuserve.com
3 
Lisa Holland 
NFIP State Coordinator 
South Carolina Department of Natural 
Resources 
Suite 222 
2221 Devine Street 
Columbia, SC 29205 
(803) 734-9120 
(803) 734-9200 FAX 
holland@water.dnr.state.sc.us 
Brett Hulsey 
Director 
Protect Our Families From Floods Project 
Sierra Club Midwest Office 
Suite 203 
214 North Henry Street 
Madison, WI 53703-3201 
(608) 257-4994 
(608) 256-4562 FAX 
brett.hulsey@sierraclub.org 
Christopher P. Jones, P.E. 
Chair 
Flood Committee 
American Society of Civil Engineers 
2513 Smithfield Road 
Charlottesville, VA 22901 
(804) 296-4303 
(804) 296-4201 FAX 
cjones@cstone.net 
Richard Krimm 
Retired, Federal Emergency 
Management Agency 
Unit 603 
700 New Hampshire Avenue, NW 
Washington, DC 20037 
(202) 333-1205 
(202) 965-3857 FAX 
rkrimm@aol.com 
Jon Kusler 
Executive Director 
Association of State Wetland Managers 
P.O. Box 269 
Berne, NY 12023-9746 
(518) 872-1804 
(518) 872-2171 FAX 
aswm@aswm.org 
Larry Larson 
Executive Director 
Association of State Floodplain Managers 
Suite 204 
2809 Fish Hatchery Road 
Madison, WI 53713 
(608) 274-0123 
(608) 274-0696 FAX 
Larry@floods.org 
Wendy Lathrop 
Technical Mapping Advisory Council 
319 Llandrillo Road 
Bala Cynwyd, PA 19004 
(610) 667-3416 
w-lathrop@usa.net 
Albert LeQuang 
Manager 
Insurance Standards and Disaster Mitigation 
Mortgage Credit Policy Department 
Freddie Mac 
MS 289 
8200 Jones Branch Drive 
McLean, VA 22102 
(703) 903-2103 
(703) 903-2814 FAX 
al_lequang@freddiemac.com
4 
William Merrell 
President 
H. John Heinz III Center for Science, 
Economics, and the Environment 
Suite 735 South 
1001 Pennsylvania Avenue, NW 
Washington, DC 20004 
(202) 737-6307 
(202) 737-6410 FAX 
merrell@heinzctr.org 
Michael J. Moye 
President 
Bank of America Insurance Services, Inc. 
505 East Market Street 
Leesburg, VA 20176 
(703) 443-2334 
(703) 443-2335 FAX 
nLic100@aol.com 
Phil Oshida 
Deputy Director 
Wetlands Division 
U.S. Environmental Protection Agency 
1200 Pennsylvania Avenue, NW 
Washington, DC 20460 
(202) 260-6045 
(202) 260-2356 FAX 
oshida.phil@epa.gov 
Doug Plasencia, P.E. 
Associate 
Kimley-Horn & Associates 
Suite 250 
7600 North 15th Street 
Phoenix, AZ 85020 
(602) 944-5500 
(602) 997-9764 FAX 
dplasencia@phx.kimley-horn.com 
James Sadler, CPCU 
Vice President 
National Con-Serv, Inc. 
Suite 408 
451 Hungerford Drive 
Rockville, MD 20850 
(800) 368-7720, ext. 9607 
(301) 279-0364 FAX 
jsadler@ncsi-net.com 
Tim Searchinger 
Senior Attorney 
Environmental Defense 
Suite 1016 
1875 Connecticut Avenue, NW 
Washington, DC 20009 
(202) 387-3500 
(202) 234-6049 FAX 
timsearchinger@environmentaldefense.org 
John R. Sheaffer 
Chairman 
Sheaffer International L.L.C. 
40 Shuman Boulevard 
Naperville, IL 60563 
(630) 548-1980 
(630) 548-1983 FAX 
jsheaffer@sheafferinternational.com 
Frank H. Thomas 
Mitigation Consultant 
176 Noya Point 
Loudon, TN 37774 
(865) 458-1791 
(865) 458-0481 FAX 
fhthomas@chartertn.net 
Jerry Uhlmann 
Director 
Missouri Emergency Management Agency 
2302 Militia Drive 
P.O. Box 116 
Jefferson City, MO 65102 
(573) 526-9101 
(573) 634-7966 FAX 
juhlmann@mail.state.mo.us
5 
French Wetmore 
President 
French & Associates, Inc. 
153 Nanti Street 
Park Forest, IL 60466 
(708) 747-5273 
(708) 747-5279 FAX 
frenchasoc@aol.com 
Gilbert F. White 
Professor of Geography 
University of Colorado at Boulder 
Campus Box 482 
Boulder, CO 80309-0482 
(303) 492-6311 
(303) 492-2151 FAX 
gilbert.white@colorado.edu 
Thomas H. Yorke 
Chief 
Office of Surface Water 
U.S. Geological Survey 
MSC 415 
12201 Sunrise Valley Drive 
Reston, VA 20192 
(703) 648-5305 
(703) 648-5722 FAX 
thyorke@usgs.gov 
FEMA STAFF 
Michael J. Armstrong 
Associate Director for Mitigation 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-3003 
michael.armstrong@fema.gov 
Martha Braddock 
Director 
Office of Intergovernmental Affairs 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-4515 
martha.braddock@fema.gov 
Michael Buckley 
Technical Services Division Director 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-2756 
mike.buckley@fema.gov 
Jane Bullock 
Chief of Staff 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-3923 
jane.bullock@fema.gov 
Carl Cook 
Mitigation Division Director 
Region X 
Federal Emergency Management Agency 
130 228th Street, SW 
Bothell, WA 98021-9796 
(425) 487-4687 
carl.cook@fema.gov 
Joe Coughlin 
Program Analyst 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-3449 
joseph.coughlin@fema.gov
6 
Brian Cowan 
Program Analyst 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-2821 
brian.cowan@fema.gov 
Donna M. Dannels 
Acting Division Director 
Program Assessment and Outreach Division 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-3662 
donna.dannels@fema.gov 
Vincent Fabrizio 
Congressional Liaison Specialist 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-4500 
vince.fabrizio@fema.gov 
Terry Fell 
Mitigation Program Branch Chief 
Region V 
Federal Emergency Management Agency 
Sixth Floor 
536 South Clark Street 
Chicago, IL 60605 
(312) 408-5587 
terry.fell@fema.gov 
Matthew Furman 
Director 
Office of Public Affairs 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-4600 
matthew.furman@fema.gov 
Ron Grimes 
Director 
Office of Legislative and 
Congressional Affairs 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-4500 
ron.grimes@fema.gov 
George Haddow 
Deputy Chief of Staff 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-3291 
george.haddow@fema.gov 
David Holst 
Program Specialist 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-3444 
david.holst@fema.gov 
JoAnn Howard 
Federal Insurance Administrator 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-2781 
joann.howard@fema.gov 
Laurel Lacy 
Program Analyst 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-3590 
laurel.lacy@fema.gov
7 
Margaret Lawless 
Deputy Associate Director for Mitigation 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-3027 
margaret.lawless@fema.gov 
Howard Leikin 
Deputy Administrator 
Federal Insurance Administration 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-2784 
howard.leikin@fema.gov 
Brad Loar 
Mitigation Program Branch Chief 
Region IV 
Federal Emergency Management Agency 
3003 Chamblee Tucker Road 
Atlanta, GA 30341 
(554) 220-5416 
brad.loar@fema.gov 
Claudia Murphy 
Program Analyst 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-2775 
claudia.murphy@fema.gov 
Michael Robinson 
Acting Chief 
Program Policy Branch 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-2716 
mike.robinson@fema.gov 
Mary Jo Vrem 
Congressional Liaison Specialist 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-4500 
mary.jo.vrem@fema.gov 
James L. Witt 
Director 
Federal Emergency Management Agency 
500 C Street, SW 
Washington, DC 20472 
(202) 646-3923 
james.witt@fema.gov 
MAC STAFF 
Lisa Kaplan, CMP 
Project Manager 
Management Assistance Corporation 
Suite 351 
11900 Parklawn Drive 
Rockville, MD 20852-2624 
(301) 468-6004, ext. 433 
(301) 468-0338 FAX 
Lkaplan@mac1988.com
Appendix B 
Agenda
FEDERAL EMERGENCY MANAGEMENT AGENCY 
Floodplain Management Forum 
The Madison Hotel 
Washington, DC 
June 8, 2000 
AGENDA 
7:30 a.m. – 8:00 a.m. Coffee/Registration 
8:00 a.m. – 8:45 a.m. Opening Remarks 
James L. Witt, Director 
8:45 a.m. – 9:00 a.m. Opening Remarks 
Michael J. Armstrong, Associate Director for Mitigation 
JoAnn Howard, Federal Insurance Administrator 
9:00 a.m. – 10:15 a.m. 5-Minute Statements From Each Participant 
10:15 a.m. – 10:30 a.m. Break 
10:30 a.m. – 12 noon 5-Minute Statements From Each Participant (continued) 
12 noon – 1:00 p.m. Lunch (in Groups: Mapping, Floodplain Management, Insurance) 
1:00 p.m. – 1:45 p.m. Facilitated Discussion: Mapping 
1:45 p.m. – 2:30 p.m. Facilitated Discussion: Insurance 
2:30 p.m. – 2:45 p.m. Break 
2:45 p.m. – 3:30 p.m. Facilitated Discussion: Floodplain Management 
3:30 p.m. – 4:00 p.m. Wrap-Up