Crossover Guide
C
Associating Community Rating System Planning Steps to the Hazard Mitigation Planning Process Version 1.0
Hazard Mitigation Planning Regulations (44 CFR 201.6) Phase I − Planning process 201.6(c)(1) 201.6(b)(1) 201.6(b)(2) & (3) Phase II − Risk assessment 201.6(c)(2)(i) 201.6(c)(2)(ii) & (iii) Phase III − Mitigation strategy 201.6(c)(3)(i) 201.6(c)(3)(ii) 201.6(c)(3)(iii) Phase IV − Plan maintenance 201.6(c)(5) 201.6(c)(4)
Community Rating System Planning Steps
Maximum Points
1. Organize 2. Involve the public 3. Coordinate
10 85 25
4. Assess the hazard 5. Assess the problem
20 35
6. Set goals 7. Review possible activities 8. Draft an action plan
2 30 70
9. Adopt the plan 10. Implement, evaluate, revise Total
2 15 294
Colorado Division of Emergency Management Department of Local Affairs, 9195 East Mineral Avenue, Suite 200, Centennial, Colorado 80112 Phone: (720) 852‐6695 | FAX (720) 852‐6750 | dola.colorado.gov/dem
Crossover Guide: Associating Community Rating System Planning Steps to the Hazard Mitigation Planning Process
Table of Contents
Purpose
Purpose...................................................................i Scope ......................................................................i Outcome .................................................................i How to Use This Guide ..........................................ii References .............................................................ii Acknowledgements ...............................................ii Crossover Guide Step 1 – Organize...................................................1 Step 2 – Involve the Public ....................................1 Step 3 – Coordinate ...............................................3 Step 4 – Assess the Hazard ....................................5 Step 5 – Assess the Problem..................................6 Step 6 – Set Goals ..................................................8 Step 7 – Review Possible Activities........................9 Step 8 – Draft an Action Plan...............................10 Step 9 – Adopt the Plan.......................................11 Step 10 – Implement, Evaluate, Revise ...............12
To provide community floodplain managers and other hazard mitigation professionals with a tool to help receive Community Rating System (CRS) planning credit through FEMA’s multi‐hazard mitigation planning process.
Scope Floodplain management planning is designed to produce a program of activities that best address a community’s hazard vulnerability and meet other community needs. Under the National Flood Insurance Program’s (NFIP) Community Rating System, flood insurance premiums are adjusted to reflect community activities that:
Reduce flood damage to existing buildings. Manage development in areas not mapped by the NFIP. Protect new buildings beyond the minimum NFIP protection level. Help insurance agents obtain flood data. Help people obtain flood insurance.
The objective of providing credit for floodplain management planning is to ensure that a process is followed to select the best mitigation measures for the community and its hazards. A community’s FEMA approved multi‐hazard mitigation plan may receive CRS credit if it was prepared in accordance with the process explained in the NFIP CRS Coordinator’s Manual or FEMA’s Local Multi‐Hazard Mitigation Planning Guidance.
Outcome
The desired outcome of using this crossover guide is for a community to receive CRS planning credit and the associated points. This CRS credit would come from submitting an existing FEMA approved Multi‐ Hazard Mitigation Plan or by following the mitigation planning process with paying special attention to the related CRS steps.
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Crossover Guide: Associating Community Rating System Planning Steps to the Hazard Mitigation Planning Process
For every 500 CRS points a community earns, insurance premiums are adjusted downward to reflect the higher amount of planning in place to reduce the impact of flood hazards on the community. Some communities may reach the next 500 point threshold by earning CRS planning credit.
How to Use This Guide This guide intends to provide assistance on how steps for mitigation planning intersect with the steps required for CRS floodplain management planning. The crossover guide is a matrix of five columns that associate the CRS planning steps with the appropriate mitigation planning step. The column names and descriptions are as follows: Mitigation Plan Step ‐ Multi‐hazard mitigation planning regulations from the Disaster Mitigation Act (44 CFR 201.6). Indicated in red text are the required planning areas for local mitigation plans plans. Language in this column reflects excerpts from the Local Mitigation Plan Review Crosswalk. CRS Step – CRS 10‐step process and related subcomponents. Included in this column is a description of required CRS planning elements that are indicated by the red text. Points ‐ Maximum number of points possible per CRS step. This information is included so the user may determine the relative value of pursuing a particular planning activity. Crossover ‐ Consistency between CRS and mitigation planning steps as indicated with a Yes, No, Maybe. Yes) the mitigation planning process should adequately represent the CRS planning requirement.
Maybe) the mitigation planning process may partially address the CRS requirement or even when addressed, may still be inadequate to gain maximum CRS points for the step. Mitigation Planning Comments ‐ A practitioner perspective of what to expect in the mitigation planning process and how it may affect CRS points.
References
Coordinators Manual, National Flood Insurance Program Community Rating System, FEMA 2007 Example Plans, National Flood Insurance Program Community Rating System, FEMA 2007 Local Multi‐Hazard Mitigation Planning Guidance, FEMA 2008 Mitigation Planning Workshop for Preparing and Reviewing Local Plans, Student Manual, Emergency Management Institute, Course Code: G‐318
Acknowledgements Special thanks go to members of the CDEM Mitigation Team for making this guide a viable tool for local partners. In addition, community planners from the FEMA Region VIII Mitigation Section and a Community Rating System expert from ISO made invaluable contributions to this guide.
No) rarely is the mitigation planning process sufficient in meeting the CRS planning requirement.
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Crossover Guide: Associating Community Rating System Planning Steps to the Hazard Mitigation Planning Process Mitigation Plan Step
CRS Step
Phase I – Planning Process
4 ‐ 201.6(c)(1): The plan shall document the planning process used to develop the plan, including how it was prepared, who was involved in the process, and how the public was involved. 4A: Does the plan provide a narrative description of the process followed to prepare the new or updated plan? (REQUIRED)
1. Organize to prepare the plan The document must discuss how it was prepared, who was involved in the planning process, and how the public was involved during the planning process. (REQUIRED)
Points
Crossover
Mitigation Planning Comments
10
Yes
4B: Does the new or updated plan indicate who was involved in the current planning process? (For example, who led the development at the staff level and were there any external contributors such as contractors? Who participated on the plan committee, provided information, reviewed drafts, etc.?) (REQUIRED)
a.
Process is under supervision or direction of a professional planner.
2
Yes
Typically, an emergency manager or planning consultant will facilitate the planning process and the development of the plan document. Emergency managers engage in the professional development of response, recovery, mitigation, continuity, and many other types of plans; however, they are rarely professional planners.
4B: Does the new or updated plan indicate who was involved in the current planning process? (For example, who led the development at the staff level and were there any external contributors such as contractors? Who participated on the plan committee, provided information, reviewed drafts, etc.?) (REQUIRED)
b.
Planning committee of department staff that will be involved in implementation.
6
Yes
Stakeholder identification is a standard step in the planning process. At a minimum, entities with assigned or potential actions are represented on the committee. Direct involvement of floodplain related stakeholders (special districts, engineers, floodplain managers) is highly encouraged. Participation may vary but are typically included in at least a review capacity.
c.
Process or committee are formally created or recognized by action of the community’s governing board.
2
Maybe
Sometimes MOAs or MOUs are signed to formally create a planning committee and outline their responsibilities, or among different jurisdictions in a multi‐jurisdictional plan.
2. Involve the public The planning process must include an opportunity for the public to comment on the plan during the drafting
85
4 ‐ 201.6(c)(1): The plan shall document the planning process used to develop the plan, including how it was prepared, who was involved in the process, and how the public was involved.
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Crossover Guide: Associating Community Rating System Planning Steps to the Hazard Mitigation Planning Process Mitigation Plan Step
CRS Step
Points
Crossover
Mitigation Planning Comments
40
Maybe
Generally the core planning committee consists of departmental staff or other subject matter experts from stakeholder entities. Stakeholder groups such as Home Owner Associations or individual citizens are sometimes invited and participate on the planning committee. However, the public are rarely direct members of the planning committee. A subcommittee consisting of members of the public could be one tool used to meet this requirement. The number of members of the public on this subcommittee must be equal to the number of departmental staff or other non‐public stakeholders to receive full CRS credit, otherwise points will be prorated.
15
Maybe
Typically there is a public kick‐off meeting that describes the planning process and solicits public input on view of hazards, their impacts, and what can be done about them. Presenting the Multi‐ Hazard Mitigation Plan at an established forum such as a Planning Commission or County Commissioners’ meeting is a recommended strategy to also achieve public attendance.
stage and prior to plan approval. (REQUIRED) 4B: Does the new or updated plan indicate who was involved in the current planning process? (For example, who led the development at the staff level and were there any external contributors such as contractors? Who participated on the plan committee, provided information, reviewed drafts, etc.?) (REQUIRED)
a.
Planning process conducted through a planning committee that includes members of the public.
If same as committee referenced in step 1‐C, then at least ½ must be representatives of the public. The term “public” includes residents, businesses, property owners, and tenants in the floodplain and other known hazard areas. The term “public” also includes stakeholders such as business leaders, civic groups, academia, non‐profit organizations, and large employers.
4C: Does the new or updated plan indicate how the public was involved? (Was the public provided an opportunity to comment on the plan during the drafting stage and prior to the plan approval?) (REQUIRED)
Held in the affected area(s) and at least one meeting separate from planning committee.
4C: Does the new or updated plan indicate how the public was involved? (Was the public provided an opportunity to comment on the plan during the drafting stage and prior to the plan approval?) (REQUIRED)
c. Public meetings held for input on draft plan. At least one toward end of planning process and at least 2 weeks before submittal to community governing body.
15
Yes
Public input is required for FEMA approval; however, the opportunity for public review is not required to be in the form of a meeting. There is often a public review upon completion of draft risk assessment and another public review of the final draft.
4C: Does the new or updated plan indicate how the public was involved? (Was the public provided an opportunity to comment on the plan during the drafting stage and prior to the plan approval?) (REQUIRED)
d.
5
Maybe
It is becoming more common for questionnaires or surveys to be distributed at the beginning of the planning process to solicit comments or to gain understanding of public perception of risks and priorities.
b.
Public Meetings held at the beginning of the planning process.
Questionnaires ask the public for information on hazards, problems, and solutions.
Must be distributed to at least 90% of floodplain residents.
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Crossover Guide: Associating Community Rating System Planning Steps to the Hazard Mitigation Planning Process Mitigation Plan Step 4D: Does the new or updated plan discuss the opportunity for neighboring communities, agencies, businesses, academia, nonprofits, and other interested parties to be involved in the planning process? (REQUIRED)
4C: Does the new or updated plan indicate how the public was involved? (Was the public provided an opportunity to comment on the plan during the drafting stage and prior to the plan approval?) (REQUIRED)
4 ‐ 201.6(b): In order to develop a more comprehensive approach to reducing the effects of natural disasters, the planning process shall include: (2) An opportunity for neighboring communities, local and regional agencies involved in hazard mitigation activities, and agencies that have the authority to regulate development, as well as businesses, academia and other private and non‐profit interests to be involved in the planning process; and (3) Review and incorporation, if appropriate, of existing plans, studies, reports, and technical information.
CRS Step e.
Recommendations are solicited from advisory groups, etc.
Points
Crossover
Mitigation Planning Comments
5
Maybe
Questionnaires or surveys and one‐on‐one meetings are sometimes used to solicit comments or to gain understanding of advisory group perception and priorities.
5
Maybe
Sometimes methods such as public websites, newspaper articles/notices, kiosks, and presentations to councils, attendance at county fairs and other public events are used to engage the public in the planning process. Online surveys are another tool used during this step.
25
E.g., neighborhood groups, homeowner associations, parent‐teacher groups, Chamber of Commerce, etc. f.
Other public information activities to explain the process and encourage input.
3. Coordinate with other agencies Other agencies and organizations must be contacted to see if they are doing anything that may affect or support the community’s program or efforts. To receive credit for this step, coordination must include items (a) and (b).
4E: Does the planning process describe the review and incorporation, if appropriate, of existing plans, studies, reports, and technical information? (REQUIRED)
a.
Review of existing studies, reports, plans, and technical information and of the needs, goals, and plans for the community. (REQUIRED)
3
Yes
Review of items such as land use codes, community plans, strategic plans, Emergency Operations Plans and existing mitigation plans and hazard specific studies is a common practice.
4D: Does the new or updated plan discuss the opportunity for neighboring communities, agencies, businesses, academia, nonprofits, and other interested parties to be involved in the planning process? (REQUIRED)
b.
Invited neighboring communities and other agencies. (REQUIRED)
1
Yes
These entities are identified during the stakeholder analysis and are typically invited to participate in the process either as a committee member or by reviewing planning elements throughout the process.
E.g., local and regional agencies involved in hazard mitigation, land use/development agencies, businesses, academia, etc.
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Crossover Guide: Associating Community Rating System Planning Steps to the Hazard Mitigation Planning Process Mitigation Plan Step
CRS Step
4D: Does the new or updated plan discuss the opportunity for neighboring communities, agencies, businesses, academia, nonprofits, and other interested parties to be involved in the planning process? (REQUIRED) 15 ‐ 201.6(c)(3)(ii): The mitigation strategy must also address the jurisdiction’s participation in the National Flood Insurance Program (NFIP), and continued compliance with NFIP requirements, as appropriate.
c.
Contacted neighboring communities and agencies responsible for NFIP and other emergency management activities.
Points
Crossover
Mitigation Planning Comments
4
Yes
Local planning committees often request this type of information from the state. The crosswalk requires that administration of the NFIP program be described and the type and number of repetitive loss properties be presented. In addition, all jurisdictions that participate in the NFIP have to adopt a mitigation action that commits to continuing or improving the program.
4
Maybe
It is encouraged that these organizations are engaged, however participation of specific organizations tend to vary by jurisdiction and related need.
Occurs at the beginning of process to see if they are doing anything that may affect or support the community’s program or efforts.
4D: Does the new or updated plan discuss the opportunity for neighboring communities, agencies, businesses, academia, nonprofits, and other interested parties to be involved in the planning process? (REQUIRED)
d.
Contacted other governmental or nongovernmental agencies.
E.g., National Weather Service, American Red Cross, homebuilders associations, etc. to see if they are doing anything that may affect or support the community’s program or efforts.
4D: Does the new or updated plan discuss the opportunity for neighboring communities, agencies, businesses, academia, nonprofits, and other interested parties to be involved in the planning process? (REQUIRED) 4E: Does the planning process describe the review and incorporation, if appropriate, of existing plans, studies, reports, and technical information? (REQUIRED)
e.
Coordination meetings held with agencies to review common problems, development policies, mitigation strategies, or regulatory or legal conflicts.
10
Maybe
Coordination with stakeholder agencies is a requirement. However, the topics covered during coordination meetings may not cover all areas.
4B: Does the new or updated plan indicate who was involved in the current planning process? (For example, who led the development at the staff level and were there any external contributors such as contractors? Who participated on the plan committee, provided information, reviewed drafts, etc.?) (REQUIRED))
f.
Draft action plan sent to agencies for comments.
3
Yes
It is common practice to send the plan document or provide notice of posting to a web page of committee members or other stakeholder groups to solicit review and comment.
Phase II − Risk assessment
Contacting groups under items (b), (c), (d), and (e) and asking them to comment by a certain date.
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Crossover Guide: Associating Community Rating System Planning Steps to the Hazard Mitigation Planning Process Mitigation Plan Step
CRS Step
Points
Crossover
5 ‐ 201.6(c)(2)(i): The risk assessment shall include a description of the type … of all natural hazards that can affect the jurisdiction. 6 ‐ 201.6(c)(2)(i): The risk assessment shall include a description of the … location and extent of all natural hazards that can affect the jurisdiction. The plan shall include information on previous occurrences of hazard events and on the probability of future hazard events.
4. Assess the hazard To receive credit for this step, coordination must include items (a).
20
Yes
Flood is an expected hazard to be identified in all local hazard mitigation plans.
5A: Does the new or updated plan include a description of the types of all natural hazards that affect the jurisdiction? (REQUIRED) 6A: Does the risk assessment identify the location (i.e., geographic area affected) of each natural hazard addressed in the new or updated plan? (REQUIRED) 6B: Does the risk assessment identify the extent (i.e., magnitude or severity) of each hazard addressed in the new or updated plan? (REQUIRED)
a.
Plan includes an assessment of the flood hazard. (REQUIRED)
If the community is a Category B or C repetitive loss community, this step must cover all of its repetitive loss areas. The assessment must include at least one of items (1), (2), and (3).
Mitigation Planning Comments
6A: Does the risk assessment identify the location (i.e., geographic area affected) of each natural hazard addressed in the new or updated plan? (REQUIRED)
(1) A map of known flood hazards. The floodplain shown on the FIRM or DFIRM, repetitive loss areas, areas not mapped but that have flooded in the past, and surface flooding identified in existing studies.
5
Maybe
Nearly all plans have some type of flood map. If a DFIRM exists it must be included in the plan. The required information for CRS points may or may not be included on a typical map.
5A: Does the new or updated plan include a description of the types of all natural hazards that affect the jurisdiction? (REQUIRED) 6B: Does the risk assessment identify the extent (i.e., magnitude or severity) of each hazard addressed in the new or updated plan? (REQUIRED)
(2) A description of know flood hazards. Includes source of water, depth of flooding, velocities, and warning time.
5
Maybe
Hazard profiles are required to include the definition or description, geographic location, the extent (magnitude/severity), and future probability. It is expected that the best available data be researched and used. One potential source for this data is a Flood Insurance Study (FIS) that is included with new DFIRMS or old FIRMS. However, the level of detailed needed for CRS points related to water source, depth,
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CRS Step
Points
Crossover
Mitigation Planning Comments velocities, and warning time may or may not be included or available.
6C: Does the plan provide information on previous occurrences of each hazard addressed in the new or updated plan? (REQUIRED)
5A: Does the new or updated plan include a description of the types of all natural hazards that affect the jurisdiction? (REQUIRED) 6A: Does the risk assessment identify the location (i.e., geographic area affected) of each natural hazard addressed in the new or updated plan? (REQUIRED) 6B: Does the risk assessment identify the extent (i.e., magnitude or severity) of each hazard addressed in the new or updated plan? (REQUIRED) 7 ‐ 201.6(c)(2)(ii): The risk assessment shall include a description of the jurisdiction’s vulnerability to the hazards described in paragraph (c)(2)(i) of this section. This description shall include an overall summary of each hazard and its impact on the community. 12 ‐ 201.6(c)(2)(iii): For multi‐ jurisdictional plans, the risk assessment must assess each jurisdiction’s risks where they vary from the risks facing the entire planning area. 7A: Does the new or updated plan include an overall summary description of the jurisdiction’s vulnerability to each hazard? (REQUIRED) 7B: Does the new or updated plan address the impact of each hazard on the jurisdiction? (REQUIRED)
(3) b.
A discussion of past floods.
5
Yes
Hazard profiles are required to include the history of events. However, details provided within the historic discussion may or may not include some details required for CRS.
The plan describes other natural hazards. (REQUIRED FOR DMA)
5
Yes
Profiles for all know hazards to affect the area are required and they include maps, the definition or description, geographic location, the extent (magnitude/severity), and future probability. It is expected that the best available data be researched and used.
35
2
Yes
If the plan includes a map and profile.
5. Assess the problem To receive credit for this step, coordination must include items (a) and must evaluate the hazard data in light of their impact on the community. List data, such as the names of critical facilities or number of insurance claims is not enough.
a.
Summary of vulnerability to each hazard identified in the hazard assessment and the impact on the community. (REQUIRED)
Hazard vulnerability assessments are expected to include a description of the built environment, population, economy, and environment potentially or imminently impacted. It is expected that the best available data be researched and used. Discussion should identify specific impacts on each participating jurisdiction.
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Crossover Guide: Associating Community Rating System Planning Steps to the Hazard Mitigation Planning Process Mitigation Plan Step 7 ‐ 201.6(c)(2)(ii): The risk assessment shall include a description of the jurisdiction’s vulnerability to the hazards described in paragraph (c)(2)(i) of this section. This description shall include an overall summary of each hazard and its impact on the community.
CRS Step b.
Description of the impact of the hazards on:
Points
Crossover
Mitigation Planning Comments
7A: Does the new or updated plan include an overall summary description of the jurisdiction’s vulnerability to each hazard? (REQUIRED) 7B: Does the new or updated plan address the impact of each hazard on the jurisdiction? (REQUIRED)
(1)
Life, safety, health, procedures for warning and evacuation.
5
Maybe
Typically, impact to life is covered if there is a population vulnerable to the hazard as it the highest priority for mitigation. Inclusion of other health, safety, or need for warning and evacuation is desired but will vary from plan to plan.
9A: Does the new or updated plan describe vulnerability in terms of the types and numbers of existing buildings, infrastructure, and critical facilities located in the identified hazard areas? (RECOMMENDED) 9B: Does the new or updated plan describe vulnerability in terms of the types and numbers of future buildings, infrastructure, and critical facilities located in the identified hazard areas? (RECOMMENDED)
(2)
Critical facilities and infrastructure.
5
Maybe
A discussion of types and numbers of critical facilities or infrastructure is typically included; however, the level of detail varies depending on stakeholder participation, the associated comfort level of disclosure or legal limitations, or availability of data or information.
10 ‐ 201.6(c)(2)(ii)(B): The plan should describe vulnerability in terms of an estimate of the potential dollar losses to vulnerable structures identified in paragraph (c)(2)(ii)(A) of this section and a description of the methodology used to prepare the estimate … . 10A: Does the new or updated plan estimate potential dollar losses to vulnerable structures?
(3)
The community’s economy and tax base.
5
Maybe
Potential dollar losses to facilities and infrastructures should be included but are not required. Many communities are using FEMA’s HAZUS‐MH to develop flood loss estimates. Also, some Multi‐Hazard Mitigation Plans describe the community’s economy and major employers in a community profile.
5
Maybe
Guidance recommends inclusion of an inventory count and description of structural information (use type, material type) to include capital improvements. Census data and county assessor’s data, DFIRMS and the accompanying FIS are all
9A: Does the new or updated plan describe vulnerability in terms of the types and numbers of existing buildings, infrastructure, and critical facilities located in the identified hazard areas? (RECOMMENDED)
c.
Number and types of buildings subject to the hazards.
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Crossover Guide: Associating Community Rating System Planning Steps to the Hazard Mitigation Planning Process Mitigation Plan Step
CRS Step
Points
Crossover
9B: Does the new or updated plan describe vulnerability in terms of the types and numbers of future buildings, infrastructure, and critical facilities located in the identified hazard areas? (RECOMMENDED)
Mitigation Planning Comments potential sources for this type of analysis. HAZUS has this information (currently Census 2000, soon to be Census 2010) at the county and municipal levels. Level of detail will vary from plan to plan.
8 ‐ 201.6(c)(2)(ii): The risk assessment must also address National Flood Insurance Program (NFIP) insured structures that have been repetitively damaged floods. 8A: Does the new or updated plan describe vulnerability in terms of the types and numbers of repetitive loss properties located in the identified hazard areas? (REQUIRED) 10A: Does the new or updated plan estimate potential dollar losses to vulnerable structures? (RECOMMENDED)
d. Review of all flood insurance claims. All properties that have received flood insurance claims (In addition to repetitive loss properties) or an estimate of potential dollar loss to vulnerable structures.
4
Maybe
Guidance recommends including an estimate of potential dollar losses for structures, contents, functional loss, and displacement and the associated methodology to achieve the results. Completeness of discussion varies largely between local plans and is often omitted. Repetitive loss property discussion will typically include a discussion of loss or total claims. CDEM and the CWCB can both assist in acquiring aggregated information related to flood insurance claims.
7A: Does the new or updated plan include an overall summary description of the jurisdiction’s vulnerability to each hazard? (REQUIRED) 7B: Does the new or updated plan address the impact of each hazard on the jurisdiction? (REQUIRED)
e.
4
No
This information is rarely included and is probably an afterthought in the planning process. On occasion, local public property such as parks and open space is discussed with regard to loss of function and associated revenue.
5
Maybe
Guidance suggests reviewing comprehensive and capital improvement plans, discussing future growth areas with land use planners, reviewing census data, and describing location and intensity of new development. The base of this data is sometimes captured in a community profile. The Colorado Demography Office provides regional profiles with some of this information.
Areas providing natural and beneficial functions.
E.g., wetlands, riparian areas, sensitive areas, and habitat for rare or endangered species.
11 ‐ 201.6(c)(2)(ii)(C): The plan should describe vulnerability in terms of providing a general description of land uses and development trends within the community so that mitigation options can be considered in future land use decisions. 11A: Does the new or updated plan describe land uses and development trends? (RECOMMENDED)
f.
Development, redevelopment, and population trends.
Includes a discussion of what the future brings for development, the watershed, and natural resource areas.
Phase III − Mitigation strategy
13 ‐ 201.6(c)(3)(i): The hazard mitigation strategy shall include a description of mitigation goals to reduce or avoid long‐term
6. Set goals (REQUIRED) Statement of goals of the community’s floodplain
2
Yes
Goals are standard and included in every approved plan. This is an important step as it ties directly to the scoring used for FEMA’s Hazard
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Crossover Guide: Associating Community Rating System Planning Steps to the Hazard Mitigation Planning Process Mitigation Plan Step
CRS Step
vulnerabilities to the identified hazards.
management or hazard mitigation program.
14 ‐ 201.6(c)(3)(ii): The mitigation strategy shall include a section that identifies and analyzes a comprehensive range of specific mitigation actions and projects being considered to reduce the effects of each hazard, with particular emphasis on new and existing buildings and infrastructure.
7. Review possible activities The plan must describe those activities that were considered and note why they were or were not recommended (e.g., cost‐effectiveness, not supporting community goals, etc.).
Points
Crossover
Mitigation Planning Comments Mitigation Assistance grant program applications.
30
Actions must discuss a comprehensive range of mitigation actions, such as the types of CRS activities listed in steps a‐f, that will protect new and existing buildings and infrastructure with specific actions presented for each hazard. Guidance provides a process for evaluating and prioritizing actions (i.e., STAPLEE: socially, technically, administratively, politically, legally, economically, and environmentally practical).
14A: Does the new or updated plan identify and analyze a comprehensive range of specific mitigation actions and projects for each hazard? (REQUIRED)
a. Preventative activities E.g., zoning, stormwater management regulations, building codes, and preservation of open space.
5
Maybe
Prevention activities are often included as mitigation activities, specifically for NFIP communities, e.g. updating floodplain ordinances. Often these may be “soft” activities such as reviewing or evaluating for gaps. These are seen as short to medium‐term and highly achievable.
14B: Do the identified actions and projects address reducing the effects of hazards on new buildings and infrastructure? (REQUIRED) 14C: Do the identified actions and projects address reducing the effects of hazards on existing buildings and infrastructure? (REQUIRED)
b. Property protection activities E.g., acquisition, retrofitting, and flood insurance.
5
Maybe
Property protection activities are often included as mitigation activities. These are typically included if there is a desire to submit a project application for funding through FEMA’s Hazard Mitigation Assistance grant program.
14A: Does the new or updated plan identify and analyze a comprehensive range of specific mitigation actions and projects for each hazard? (REQUIRED)
c. Natural resource protection activities E.g., wetlands, riparian, open space protection.
5
Maybe
Not every plan has every category of mitigation action as laid out in CRS but they are generally addressed for each hazard. While primarily a property protection activity, property acquisition can also contribute to improved wetland or riparian area health and benefits.
14A: Does the new or updated plan identify and analyze a comprehensive range of specific mitigation actions and projects for each hazard? (REQUIRED)
d. Emergency services activities E.g., warning and sandbagging.
5
Maybe
Tornado sirens are often included as actions in areas of Colorado along and east of the Front Range. Flood warning systems, including networks of stream and rain gages, as well as enhanced coordination with the NWS, have been
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Crossover Guide: Associating Community Rating System Planning Steps to the Hazard Mitigation Planning Process Mitigation Plan Step
CRS Step
Points
Crossover
Mitigation Planning Comments included in some plans.
14A: Does the new or updated plan identify and analyze a comprehensive range of specific mitigation actions and projects for each hazard? (REQUIRED)
e. Structural projects E.g., reservoirs, detention ponds, channel modifications.
5
Maybe
Structural activities are often included as mitigation activities. These are typically included if already depicted in the capital improvement plan or if there is a desire to submit a project application for funding through FEMA’s Hazard Mitigation Assistance grant program.
14A: Does the new or updated plan identify and analyze a comprehensive range of specific mitigation actions and projects for each hazard? (REQUIRED)
f. Public information activities E.g., outreach projects and environmental education programs.
5
Maybe
Public education activities are often included as mitigation activities, but are not required and are not always included. These are seen as short to medium‐term and highly achievable.
70
16 ‐ 201.6(c)(3)(iii): The mitigation strategy section shall include an action plan describing how the actions identified in section (c)(3)(ii) will be prioritized, implemented, and administered by the local jurisdiction. Prioritization shall include a special emphasis on the extent to which benefits are maximized according to a cost benefit review of the proposed projects and their associated costs. 17 ‐ 201.6(c)(3)(iv): For multi‐ jurisdictional plans, there must be identifiable action items specific to the jurisdiction requesting FEMA approval or credit of the plan.
8. Draft an action plan (REQUIRED) The action plan specifies those activities appropriate to the community’s resources, hazards, and vulnerable properties. For each recommendation, the action plan must: ‐ Identify who does what, when it will be done, and how it will be financed. ‐ Be prioritized. ‐ Include a review of the benefits and costs. If the plan calls for property acquisition, there must be a discussion on how the projects will be managed and how the land will be reused. Multi‐jurisdictional plans must have action items from at least two of the six categories.
The Mitigation Strategy must include how the actions were prioritized and how they will be implemented. The prioritization process used must include a review of the costs versus the benefits. Most plans provide the responsible party, source of funding, and timeline to complete the actions.
14A: Does the new or updated plan identify and analyze a comprehensive range of specific mitigation actions and projects for each hazard? (REQUIRED)
a.
Recommendations for flood‐related activities from two of the six categories
10
Maybe
Flood specific or all‐hazard actions may cover two of the categories.
14A: Does the new or updated plan identify and analyze a comprehensive
b.
Recommendations for flood‐related activities
20
Maybe
Flood specific or all‐hazard actions may cover
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range of specific mitigation actions and projects for each hazard? (REQUIRED)
Points
Crossover
Mitigation Planning Comments three of the categories.
from three of the six categories
14A: Does the new or updated plan identify and analyze a comprehensive range of specific mitigation actions and projects for each hazard? (REQUIRED)
c.
Recommendations for flood‐related activities from four of the six categories
30
Maybe
Flood specific or all‐hazard actions may cover four of the categories.
14A: Does the new or updated plan identify and analyze a comprehensive range of specific mitigation actions and projects for each hazard? (REQUIRED)
d.
Recommendations for flood‐related activities from five of the six categories
45
Maybe
Flood specific or all‐hazard actions may cover five of the categories.
14A: Does the new or updated plan identify and analyze a comprehensive range of specific mitigation actions and projects for each hazard? (REQUIRED)
e.
Post‐disaster mitigation policies and procedures
10
Maybe
Although not common, some plans may include an action triggering a plan or risk assessment review upon conclusion of a disaster event. Also, some plans include a Capability Assessment, which may include a review of pre‐ and post‐ disaster mitigation policies and procedures.
14A: Does the new or updated plan identify and analyze a comprehensive range of specific mitigation actions and projects for each hazard? (REQUIRED)
f.
Natural resource recommendations included from Habitat Conservation Plan
10
No
Rarely is this an actionable consideration in local plans.
14A: Does the new or updated plan identify and analyze a comprehensive range of specific mitigation actions and projects for each hazard? (REQUIRED)
g. Action items for mitigation of other hazards Other than public information activities.
5
Yes
Actions are included for each identified hazard.
Phase IV − Plan maintenance
1 ‐ 201.6(c)(5): The local hazard mitigation plan shall include documentation that the plan has been formally adopted by the governing body of the jurisdiction requesting approval of the plan (e.g., City Council, County Commissioner, Tribal Council). 2 ‐ 201.6(c)(5): For multi‐jurisdictional plans, each jurisdiction requesting approval of the plan must document that it has been formally adopted.
9. Adopt the plan (REQUIRED) Includes original plan as well as amendments. Multi‐jurisdictional plans must be adopted by each community seeking CRS plan credit.
2
Yes
Participating jurisdictions have one year from time of FEMA approval of the plan to adopt. FEMA will typically give conditional approval once the plan has met the requirements. Once a resolution is provided to FEMA, the local jurisdiction will receive a formal approval letter.
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Crossover
18 ‐ 201.6(c)(4)(i): The plan maintenance process shall include a section describing the method and schedule of monitoring, evaluating, and updating the mitigation plan within a five‐year cycle.
10. Implement, evaluate and revise. To maintain credit, community must submit a copy of its annual evaluation report with its recertification each year and update the plan at least once every five years.
15
2
Maybe
Plan maintenance procedures will be included in the plan and assigned a regular schedule, however, whether recurring reports are submitted to governing bodies or are publicly released varies by jurisdiction. On occasion, plans will be amended if significant changes occur to the action plans.
13
Maybe
Often, the stakeholders identified at the beginning of the planning process, or a subset of them, will continue throughout the plan maintenance process. If the committee used is a pre‐establish one, such as the Local Emergency Planning Committee or one created via MOA or MOU, then the likelihood of a qualifying successor committee being in place increases.
18A: Does the new or updated plan describe the method and schedule for monitoring the plan, including the responsible department? (REQUIRED)
18B: Does the new or updated plan describe the method and schedule for evaluating the plan, including how, when and by whom (i.e. the responsible department)? (REQUIRED)
a.
Procedures to monitor and recommend revisions. (REQUIRED)
Includes monitoring implementation, reviewing progress, and recommending revisions in an annual evaluation report. The evaluation report must be submitted to the community’s governing body and released to the media and public. b.
Same planning committee or successor committee that qualifies under Section 511.a 2(a) does the evaluation
Total Possible Points
294
Mitigation Planning Comments
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Colorado Division of Emergency Management Department of Local Affairs 9195 East Mineral Avenue, Suite 200 Centennial, Colorado 80112 (720) 852‐6600 dola.colorado.gov/dem With Contributions From FEMA Region VIII Mitigation Division Insurance Services Office (ISO)
