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Title II, Section 205. Standard Flood Hazard Determination Forms

Subsection (b) Design and Contents, calls for the map number to be used on the determination form. We suggest this be revised to community number or map number, to allow for whichever is appropriate. Our rationale is based on ongoing FEMA activities, for example: FEMA's new consolidation of whole communities onto a single map where the communities retain their identification number while consolidation of portions of communities in special areas, e.g. Hackensack, Meadowlands, are assigned new map numbers. Our recommendation would take into account these two general

possibilities.

Subsection (d) Guarantees Regarding Information, requires that third parties providing information on a determination form guarantee the accuracy of the information. While we believe this concept is laudable, we would like to express our concern that the guarantee of accuracy can only be as good as the quality of the FEMA map given to the third party to interpret. As you know, the surveying and mapping profession has noted many deficiencies and errors with FIA FIRMS. The base maps (FIRMS) used to make flood determinations are not currently drawn to uniform map accuracy standards. This increases the chance of incorrect decisions on questionable determinations.

When a flood hazard determination on a property is questionable on the FIRM, we believe the prudent method for determining the flood hazard boundary in relation to a property is to engage the services of a registered surveyor to make the

determination in the field.

correction

With respect to subsection (e) Reliance on Previous Determination, we recommend that it be eliminated. This section does not account for physical map changes or letters of map which may have been issued since the prior determination. The flood hazard status of a site could change. In addition, if the first determination had been corrected or revised at some time, there is no way to ensure that the second version is the version relied upon in a later examination of a file. For this reason, a new determination should be made each time.

Title V, Section 501, Flood Insurance Interagency Task Force

Subsection (b) Membership calls for the establishment of an interagency task force to be known as the Flood Insurance Task Force with representation from 11 heads of relevant Federal agencies and commissions. We strongly support the formulation of

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such a task force and recommend that the "designees" of those agency heads be individuals who possess the qualifications and demonstrated knowledge and competence concerning the National Flood Insurance Program. This would serve to make the Task Force truly effective.

Title IV, Section 604, Updating of Flood Insurance Maps and Identification of Erosion Hazard Areas

Subsection (e) (2) relates to cost sharing or in-kind services of not less than 50% for a state or community that requests revision or updating of its flood insurance rate map. We believe that 50% may be excessive for some communities having small tax bases, particularly rural, and those with no industry. You may wish to allow some flexibility with the 50% to take into consideration such variations.

The legislation is vague as to whether maps provided free of charge to State coordinating agencies and community representatives participating in NFIP could be sold on a cost recovery basis by those parties. Clarification of this matter would greatly assist

states and communities.

Subsection (g) Notification, requiring publication of map change or revisions no later than 30 days after the revision is made, should greatly assist interested parties who need the information. We are particularly pleased that you provided two options--notice in the Federal Register or other comparable method. While notice in the register is beneficial to some, many users of maps do not access the Federal Register on a regular basis. One alternative to the register notice would be to provide map changes to the State agencies responsible for coordination of the NFIP. As to "obtaining" copies of changes and revisions, this process should be centralized from FEMA. We understand that local agencies are often reluctant, or in some cases refuse, to distribute such information.

As the evolution to digital mapping occurs whereby users access a digital version of the maps, dissemination of changes need to occur electronically through an electronic bulletin board system. This system would be used to post notices of changes for users to read on their computers. FEMA could send the map change information electronically to the State coordinating agencies or broadcast the information through the bulletin board mechanism directly to all users.

Relative to the requirement that erosion hazard areas be identified and legibly demarcated on the Flood Insurance Rate Maps, we have some serious concerns. Those concerns lie not with erosion hazard areas being identified but with the same FIRM base maps being used to superimpose the new data on erosion hazards. As previously stated, these maps contain errors and do not necessarily conform to map accuracy standards. Instead of remedying the situation of erosion hazard identification, we would be creating additional problems by adding one more layer of confusion upon base maps already known to be deficient. Our recommendation is that new mapping data erosion hazard areas be quality-controlled, standardized and added only to maps that are updated to meet certain specifications.

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Section 605. Technical Mapping Advisory Council

We are most supportive of this new provision calling for a Technical Mapping Advisory Council. The essence of the NFIP depends upon accurate identification and depiction of flood hazard areas on maps for insurance, mitigation and management purposes. ACSM and ASPRS would be most interested in lending its members' technical expertise to assist with mapping questions on accuracy, standards, and other issues related to the flood insurance rate maps. We applaud your insight and persistence in seeking a solution to the underlying problems with the flood insurance rate maps.

On the issue of Council representation, we understand the relevance of organizations such as the Federal National Mortgage Association, the Federal Home Loan Mortgage Corporation and that of a regulated lending institution to the NFIP, but it is unclear what role these groups are intended to play on a technical mapping committee. Is this for liaison purposes or would these groups have members that would meet the qualifications criteria stated in your bill? If the representation is mainly for liaison, these organizations might be better situated on the interagency task force described in Section 501.

The addition of Section 605 strengthens the bill. We are pleased that the qualifications section addressed the need for familiarity with the digital side of the mapping process, that is knowledge of remote sensing and geographic information systems. We also agree with the suggested involvement of the Federal Geographic Data Committee (FGDC) in a coordination role. This will help ensure that an eventual digital version of the flood insurance rate maps will be in line with other efforts at the Federal level.

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We appreciate the opportunity to provide our views on mapping related aspects contained in S. 1405, the National Flood Insurance Reform Act of 1993. Should you or your staff need additional information, please contact Nancy Parke, ACSM/ASPRS Government Affairs Director at 301/493-0200.

Richarol E. Dahlberg

Richard E. Dahlberg

President, ACSM

Sincerely,

Stanley Cr Mona

Stanley A Morain

Immediate Past President, ASPRS

COMMENTS OF JAY D. HAIR

PRESIDENT, THE NATIONAL WILDLIFE FEDERATION

Dear Senator, I urge you to co-sponsor S. 1405, recently introduced by Senator John Kerry of Massachusetts, to reform the National Flood Insurance Program (NFIP). The broad reform of the NFIP proposed by this bill will benefit Americans who directly depend on healthy riverine and coastal ecosystems, and taxpayers by reducing the costs and risks of flood damage.

The recent Mississippi River flooding and enormous losses experienced by Midwest residents underscores current weaknesses in the NFIP. Despite the availability of Federal flood insurance and NFIP requirements in many cases for property to be insured, only a small portion of residences and businesses have coverage. In other instances, insured properties that have suffered repeated past flooding were flooded yet again without efforts in the interim to reduce damage risk. In addition, some communities have allowed construction of new buildings in floodprone areas that fail to meet current NFIP standards aimed at reducing flood damage risk. As a result of such failures, the cost of flooding borne by taxpayers (especially through disaster relief and casualty loss deductions) is greatly increased.

Congress established the National Flood Insurance Program in 1968 with two purposes: to make otherwise unobtainable flood insurance available for existing flood-prone buildings; and to reduce the potential for flood damage by, among other things, encouraging communities to guide new development away from the water's edge. Unfortunately, as described by South Carolina Coastal Council Director Wayne Beam, rather than guide people away from flood-prone shorelines, currently, the NFIP "invite[s] them to move closer."

S. 1405 will remove the Federal invitation to build too close to eroding shorelines by making new Federal flood insurance policies unavailable for new development in coastal erosion hazard areas. Furthermore, through a program-funded "mitigation" program, S. 1405 helps States and communities reduce the potential for flood damage to existing buildings, especially repetitive loss properties, through a variety of activities. This includes the protection of natural areas.

S. 1405 will also authorize several critically important measures to improve participation levels and the financial condition of the NFIP. The Federal Insurance Administration recently reported that the NFIP Fund is operating with an $18 million deficit, with claims from a number of major storms yet to be paid and without considering unfiled claims from recent Midwest floods. Such deficits in the past have ultimately fallen on the U.S. taxpayer for repayments.

I have enclosed a recent article entitled, "Sweet Tradition" (National Wildlife, April/May, 1993), which discusses how availability of Federal flood insurance for development in sensitive coastal areas has contributed to loss of important sweetgrass beds necessary for one of the "oldest and most continuous African-American folk art forms in this country."

As you examine ways in which to reduce Federal expenditures, I encourage you to co-sponsor S. 1405 for its benefits to the American taxpayer and the Nation's natural ecosystems that support people and wildlife.

COMMENTS OF GILBERT F. WHITE

DISTINGUISHED PROFESSOR EMERITUS OF GEOGRAPHY

INTERIM DIRECTOR, NATURAL HAZARDS RESEARCH AND APPLICATIONS INFORMATION CENTER

The improvements in Federal flood insurance policy and procedure specified in S. 1405 are a welcome and long-overdue step toward enabling the United States to pursue a genuinely constructive program to assure economically and socially sound use of floodplains. Against the background of involvement for more than 50 years in studying flood problems, I offer two major observations on the approach which the reformed policy should take if its aims are to be realized in practice. Those observations relate to broad national policy and to testing the proposed measures. I can provide more detail if you wish.

My own concern with flood problems began with studies of water management in the Mississippi Basin in 1934 as a staff member of the Mississippi Valley Committee on the Public Works Administration. It continued as Secretary of the Land and Water Committees of the National Resources Planning Board and National Resources Committee, and as a Member of the Bureau of the Budget in the Executive Office of the President, 1935-1942. Observations in those activities led to a mono

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