ASFPM Comments to the Senate Appropriations Committee

May 4, 2015 | News & Views, What's New

Outside Witness

Senate Appropriations

Subcommittee on
Homeland Security

April 24, 2015

Comments on the
Fiscal Year 2016 Budget Request for the Federal Emergency Management Agency

Submitted by:

Association of State
Floodplain Managers

Chad Berginnis,
Executive Director

The Association of State Floodplain Managers appreciates
this opportunity to comment on aspects of the Fiscal Year 2015 FEMA Budget
Request. We wish to express the strong
support of our members for the request of $278.6 million for RiskMAP, $200
million for Pre-Disaster Mitigation and $150 million for Flood Mitigation

The Association of State Floodplain Managers and its 36
State Chapters represent more than 16,000 state and local officials and other
professionals who are engaged in all aspects of floodplain management and
hazard mitigation, including implementation of aspects of the National Flood
Insurance Program, mapping, engineering, planning, permitting, hydrology,
forecasting and management of floodplain areas. All ASFPM members are concerned
with reducing loss of life and property due to flooding. Our website is:

ASFPM members wish to thank the Subcommittee for its
prior support of mitigation/risk reduction and of risk identification. Disaster related costs to the nation continue
to rise. Flooding is the most frequent and most predictably costly type of
natural disaster that can affect every part of the country. To reduce the losses and associated costs,
hazard mitigation is key. Risk
identification (mapping) is essential to guide and direct hazard mitigation

For FY ’16, ASFPM is extremely pleased that the
Administration has focused substantial budget increases on identification of
areas at risk of flooding through RiskMAP and on reducing those risks through
Pre-Disaster Mitigation (PDM) and Flood Mitigation Assistance (FMA). This indicates to us that the Administration
is serious about curtailing the ballooning disaster costs and saving lives and

The FY ’16 request for the Pre-Disaster Mitigation program
(PDM) will support revitalization of a program which has been woefully
underfunded in recent years. Despite
earlier efforts to eliminate the program, this Subcommittee has understood the
importance of reducing the vulnerability of flood-prone properties before a
disaster occurs – saving the federal taxpayer an estimated $4 for every $1
invested in mitigation – as well as saving lives and valuable property. ASFPM members have gratefully appreciated the
Subcommittee’s repeated inclusion of funds to keep the program functioning.

Even with dramatically reduced funding in recent years,
PDM has had a positive impact on mitigation capacity and reduced losses through
its focus on two activities: all hazard mitigation planning and hazard
mitigation projects. In the absence
of mitigation funds made available after a disaster (Hazard Mitigation Grant
Program), this program provides the major support for mitigation planning and
for maintenance of the capacity to support mitigation activities. Without PDM, many states’ capacity would be
dramatically diminished as well as support for local mitigation planning.

PDM is the primary funding source for hazard mitigation
projects for states without a current disaster declaration. Demand has
historically been high for PDM – the program usually takes in applications that
exceed three times available funding. Reform of the National Flood
Insurance Program is driving interest in risk reduction actions and the
increasing need for PDM resources. Both the reform acts in 2012 and 2014 result
in flood insurance premium increasing toward full risk rates, which has driven and
will drive an unprecedented interest in flood mitigation options to lower those
premiums and risk. This is an appropriate reaction to better information about
the true risk. However, the availability of PDM funds is key to taking
advantage of this interest in mitigation, particularly in areas where there is
not a declared disaster which would make Hazard Mitigation Grant Program funds

Floodplain mapping provides not only the regulatory tool
necessary for implementation of the National Flood Insurance Program, but also
identifies areas of risk to guide mitigation activities as well as community
and economic development decisions.

FEMA’s mapping
program, RiskMAP, is funded both by appropriated funds and by fees paid by
flood insurance policyholders. This dual
source of funding is appropriate since the benefits of risk identification
accrue to the NFIP and its policyholders as well as to all taxpayers. The nation
has invested $4.3 billion in digitizing most old paper maps and in updating a
portion of the maps through new engineering studies since the effort to
modernize flood maps was initiated. Much of that engineering study work
remains to be done; many less populated areas of the country have no maps at
all and many areas still have outdated maps that do not reflect current

In response to questions about the mapping needs, ASFPM
produced a report entitled “Flood Mapping for the Nation” using the $400
million per year and additional mapping tasks authorized in the Biggert-Waters
legislation as a guide.

That report identified criteria as to what constitutes
adequate flood mapping and estimated the cost to achieve that to be a further
investment of from $4.5 billion to $7.5 billion. A subsequent steady-state cost
to then maintain accurate and up-to-date flood maps ranges from $116 million to
$275 million annually.

Against this backdrop, it is evident that at recent funding
levels, it would take a long time to achieve adequate flood mapping for the
nation. As this subcommittee is aware,
the appropriations for mapping have decreased significantly from a high point
of $220 million in FY ’10 to $95 million in FY ’14. We are well aware and very appreciative that
this Subcommittee has recognized the importance of accurate risk identification
and has found a way to appropriate funds above the recent very low budget

We are very pleased that the Administration has requested
$278.6 million for FY ’16. This investment in flood risk mapping will help to
produce more accurate and up-to-date maps. It will drive down costs and
suffering due to flooding and will provide the best tool for managing flood
risk and building sustainable communities.

Flood Mitigation Assistance (FMA) is funded by flood
insurance policy holders through the National Flood Insurance Fund (NFIF). FMA funds a variety of methods of flood
mitigation and a significant component of its funding is directed to mitigation
of Severe Repetitive Loss properties. These properties, which make numerous flood
insurance claims, sometimes even cumulatively exceeding the value of the
property, constitute a significant unnecessary drain on the NFIF. FMA was funded at $120 million in FY ’15 and
we are very pleased to see that the budget request for FY ’15 is $150 million. We urge the Subcommittee to approve this
request. Much of this money will be
wisely spent to very clearly reduce claims on the NFIF. It is
also an important source of grant funds for those seeking to reduce their flood
insurance premiums by mitigating their risk.

Because of interest expressed via language in recent
appropriations bills, ASFPM would offer some observations about the proposed
Federal Flood Risk Management Standard (FFRMS).

The President issued Executive Order 13590 on January 30,
2015 along with accompanying guidance. That guidance has been published in the
Federal Register and is now out for public comment. In response to requests for a longer time to
comment, the period was extended by 30 days and FEMA has engaged in an
energetic series of Listening Sessions around the country and by webinar to
engage public opinion and recommendations.
The FFRMS cannot be implemented until comments have been received,
studied and final guidance issued.

Even at that point, each affected federal agency will need
to take its own steps to alter rules and procedures, which will afford another
opportunity for public input – this time at the more specific level of
particular agency programs.

The changing nature of flood risk, including increased
risks due to sea level rise, demands competent standards that will withstand
the test of time and the forces of nature. We think the new EO and the FFRMS
represent an important step in that direction. In fact, some states have
already adopted statewide standards that meet or exceed the new proposed
federal standard and many, many communities and counties have done so. In these instances, the local ordinances
reflect the requirements. The new FFRMS
would not have any effect on local ordinances and would only apply where
federal funds are involved. This would
only apply to new construction or substantial repair or improvement involving
federal dollars. In some instances,
federally funded facilities have been built at levels below the local
ordinance, so in effect, this FFRMS would ensure that the federal investments
respect local ordinances and state requirements.

Thank you very much for the opportunity to make these
recommendations about FEMA’s budget for FY ’16 and to offer additional comments.
If you have any questions, please
contact ASFPM Executive Director, Chad Berginnis, at (608) 828-3000 or