Updated September 2015

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June 8, 2015 

Agency: Federal Emergency Management Agency (FEMA)
Document Type: Nonrulemaking
Title: Notice To Extend the Comment Period for the Proposed Revised Guidelines for Implementing Executive Order 11988, Floodplain Management, as Revised Through the Federal Flood Risk Management Standard
Document ID: FEMA-2015-0006-0057

Rules Docket Clerk
Docket ID FEMA-2015-0006

To Whom It May Concern:

Please know that the Policy and Legislative Committee of the Pennnsylvania Association of Floodplain Managers strongly endorses the Proposed Draft/Revised Guidelines for Implementing Executive Order 11988/13690 in its entirety. It provides a solid framework for agency decision making with regard to the proper use and management of the nation's floodplains.

We do,however, share those concerns about the Proposed Guidelines identified in the Association of State Floodplain Managers,Inc. letter of April 7,2015 to the Rules Docket Clerk on this matter. These include but are not limited to the following:
1. There is no requirement for Federal investment to follow more protective State and local standards where they exist. Agencies must go beyond just considering the higher standards specified in the Revised Guidelines for federally-funded and actions/undertaken or to be undertaken. Agencies must be required to use either state and local standards and/or either of the options specified in the FMMS whichever is higher.

2.Critical Facilities do not appear to be required to be protected to the 500 year flood event or the flood of record, whichever is higher, as recommended in the old Water Resources Council guidelines. It is essential that these facilities be required to be protected to the highest level. Critical facilities must sited and/or protected so they can be utilized in any emergency or disaster and/or post disaster situation. It will also be helpful to everyone to provide a more in-depth list of critical facilities and/or activities, although it need not be all-inclusive. 

3.Regarding the definitions in the Revised Guidelines, it is extremely important to maintain consistency with those contained in EO 11988, especially the definitions of "federal action" and "critical action". It aids in the ease of agency transition from the old to the new Guidelines. Also, the NFIP regulation term,"development", should be included in the Revised Guidelines and coordinated accordingly with the provisions therein. State and local governments are all ready familiar with this definition because of their experience with permit reviews,etc., in connection compliance with NFIP floodplain regulations.

4. State governments must be required to enact the Revised Guidelines under EO13960 as well. Federal investment is often necessary to repair and/or replace/rebuild facilities and other development that were initally financed in whole or in part with state and /or local funds,but is improperly located and/or designed and built which are subsequently damaged by flooding. This requirement should be built in as a condition for States receiving Federal Program funds such as CDBG, EPA, EDA ,USDA ,et.al.

Please know that we favor the inclusion of the approaches that include the identification and use of nature-based alternatives and the optional use of the climate-informed science approach. These are common sense approaches that can and do save money and lives in both the short term and long term accross the country.

One of our organization's primary goal is to share information and educate our members including local officials and others on sound floodplain management practices. We can do a more effective job of helping to educate our menbers and others when federal agencies demonstrate responsible floodplain management and responsible stewardship of taxpayer funds through leading by example. It becomes an uphilll challenge for an organization that is encouraging the implementation of a sound floodplain management practices in a workshop setting and a member of the audience asks why they should do it when the Federal government is doing just the opposite in the floodplain.

As Co-Chairman of the Legislative and Policy Committee and 45 years experience in floodplain mangement at the Federal, state and local level, I strongly applaud your efforts to revitalize and strengthen EO11988/13690 and the Revised Implementing Guidelines. Best wishes as you continue this very important task.

Kerry Wilson,CFM

Eric Jesperson,CFM

Co-Chairmen of the Legislative and Policy Committee
Pennsylvania Association of Floodplain Managers


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