Questions and comments from the ASFPM Flood Mitigation Committee, January 2021
The draft states that “Priority shall be given to projects that implement community-scale hazard mitigation activities that use nature-based solutions to reduce flood risk.” How is “community-scale” defined? Need clarification for this. Also perhaps a priority element for project and planning should be added for repetitive loss areas and “worst first“ prioritization language?
The draft states that “Localities shall use moneys from the Fund primarily for the purpose of implementing flood prevention and protection projects and studies in areas that are subject to recurrent flooding as confirmed by a locality-certified floodplain manager.” Does the term ‘locality-certified floodplain manager’ mean that this person must be a nationally Certified Floodplain Manager (CFM) as per ASFPM’s certification program? Would this mean that if a community doesn’t have a CFM on staff, they are ineligible for the program?
One of the guiding principles stated is “Understand fiscal realities and focus on the most cost-effective solutions for protection and adaptation of our communities, businesses and critical infrastructure.” Does the term ‘cost-effective’ indicate that there must be a Benefit Cost Analysis conducted, similar to the FEMA model for this? Could a more progressive analysis be performed instead of using FEMA’s tool? Along the same line, the draft also states “In administering the Fund, the Commonwealth will strive to ensure that as much funding as possible is allocated to flood reduction projects that will provide an appreciable flood mitigation benefit.” What exactly does the word ‘appreciable’ mean?
There are questions arising from this draft statement: “Whether it is the preservation of open space, the construction of levees and flood walls, updating stormwater or septic systems, strategically relocating homes, businesses, or infrastructure, or alternative solutions to flood risk reduction, the Fund will provide a long-term, consistent funding source to promote flood resilience in Virginia.” Levees and flood walls are not considered nature-based solutions, which has been a stated priority in the draft. How would such projects rank in the overall desirable approaches to loss reduction? And as pointed out above, how can a ‘septic system’ be considered a ‘community-scale’ project?
The draft states “Plans should also inventory critical infrastructure that may be at risk from flooding events including water supply, transportation, schools, health care, dams, levees, and other vital assets of a community and including options for adaptation, protection, or relocation.” Perhaps the use of language that speaks to the FEMA Lifelines could be used here to add consistency between both planning processes and to bring attention to the Lifelines as criteria for future project grants…
Also under planning activities is this statement: “New or updated delineations of areas of recurrent flooding, stormwater flooding and storm surge vulnerability in coastal areas that include projections for future conditions based on sea level rise, more intense rainfall events or other relevant flood risk factors.” Might want to add in “proposed future land-use” as a consideration for an approved planning activity.
Also under eligible planning activities is this: “Costs associated with staff training in the National Flood Insurance Program (NFIP), floodplain management, and Certified Floodplain Manager (CFM) designation.” May want to include training costs for building codes and/or code enforcement.
For watershed planning efforts is there a possibility to add consideration for agricultural impacts and how these may support resilience goals? Also on watershed planning efforts it may be practical to include basin level priorities to address basins and subbasins that have cumulative impact on regional flooding.
