NWC submitted comments to the Federal Emergency Management Agency in response to the draft Revised Implementing Guidelines to implement Executive Order 13690, which amended EO11988, Floodplain Management, and the new Federal Flood Risk Management Standard (FFRMS).
The new standard, applicable government-wide, covers all Federal actions, including federal investments such as the cost-shared Inland Waterways and Harbor Maintenance Trust Funds, as well as the issuance of Federal permits, licenses and approvals, which are predicated upon private investment dollars. This could include all grants, housing loans, federally-backed mortgages, highway aid, consultation requirements under Section 7 of the Endangered Species Act, and numerous other programs.
NWC’s comments, supported by numerous other organizations nationwide, note at the outset it would be entirely appropriate, and good policy, to examine the 100-year base flood elevation to ascertain whether that standard continues to provide the level of safety and protection needed to protect the millions of Americans who live and work in low lying areas. If it is determined, after a careful review, that the 100-year standard doesn’t provide the needed level of protection, then the determination of a new standard ought to include an open and transparent dialogue with state and local officials and all impacted stakeholders. As the comments point out, however, that did not occur here. Instead, critical features of the FFRMS were established behind closed doors with no public input. No information has been provided to explain the process for selection of the expanded vertical elevations and floodplain alternatives in EO 13690, nor has any fact-based analysis been revealed to justify or explain the new FFRMS levels of protection. We are concerned about the creation of a burdensome and costly federal regulatory scheme that will lead to less, not more, protection for the nearly 50% of the country who live and work in the floodplain. As a consequence, NWC calls for the FFRMS and draft implementing guidelines to be set aside and replaced with a meaningful process that includes all impacted stakeholders.
Download Full Text of Final NWC FFRMS Comments(52KB)
Numerous members of Congress have weighed in, on a bipartisan basis, expressing their concerns about both the process used to develop the FFRMS and the far-reaching impact it could have on states and local communities around the country.
Download full text of House Dear Colleague letter requesting an extension of the comment period. Bipartisan Letter on Flood EO (1,802KB)
Download full text of the House Dear Colleague letter to the President requesting information on how the FFRMS was developed. Letter to Pres on Executive Order 13690 Federal Flood Risk Management Standard(347KB)