In December, FIRM members voiced concerns over FEMA proposed changes to flood mapping process and guidelines.  FEMA considered the comments received, and as a result agreed not to eliminate SID 62 which required analyses and maps be certified by a licensed professional engineer.

The other two issues of concern related to the time period a community has to review the maps and the inclusion of wave effects in the mapping process. In the summary response, FEMA clarified language that was unclear and ultimately will be moving forward as proposed.

Thank you to all of our members who sent comments to FEMA.  Engaged and informed communities are essential to the policy-making process.

You can read our original Call to Action below and follow this link to FEMA’s summary response: FEMA GS Response to Public Comments – December 2018

 

FEMA is preparing new flood maps for Monroe County that are due to be released next year.

FIRM is very concerned about changes to the Flood Mapping Process and Guidelines being proposed by FEMA.   FIRM fears that the changes will make it possible for unproven models to be used to develop the new maps, and that the changes will prevent a fair and reasonable review of the maps.  FIRM wants to ensure that there will be adequate review time in which to defend the community’s interests.

FIRM is asking you to contact FEMA and object to these changes.

Below is sample response to FEMA drafted by FIRM.  FEMA is accepting comments through December 7, 2018, at FEMA.GS@riskmapcds.com.

You can read the full FEMA Informational Summary here: Maintenance_and_Public_Review_Announcement_2018_Risk_MAP_Guidelines_and_Standards

SAMPLE RESPONSE TO FEMA:

Subject: Risk MAP Guidelines and Standards

To Whom It May Concern:

I have great concerns about some of FEMA’s Risk MAP Guidelines and Standards proposals being made in the 2018 Annual Maintenance Cycle.

  • Standard Identification Number (SID) 62 removes the requirement that “new or updated flood hazard data” used for map generation “must be supported by modeling or sound engineering judgement and that all regulatory products must be in agreement.” Surely such a requirement is a reasonable safeguard and conflicting data should be identified and acknowledged by FEMA.
  • Standard Identification Number (SID) 138 adds a variety of specific wave effects into the mapping process without justifying their inclusion or ensuring they are not duplicative.
  • Standard Identification Number (SID) 621 requires FEMA to provide access “to the draft mapping database and any other contributing data, as requested, to the affected community’s Chief Executive Officer and Floodplain Administrator”, but limits the community’s opportunity to provide feedback of “supplemental or modifying data” to 30 days. Given the complexity of the process and the great volume of data involved, 30 days is totally inadequate.  The review period should, at the very least, be consistent with the 90-day review period offered elsewhere in the process.

Respectfully,

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