I am responding to your specific request for comments related to Local Resilience Plan criteria. At present, more than 45 communities in central and southeastern Virginia are preparing updates to their hazard mitigation plans. These plans must meet standards promulgated by FEMA and the Stafford Act, by the National Flood Insurance Program (NFIP) and the NFIP’s Community Rating System (CRS), and are reviewed by VDEM, FEMA and Verisk (for CRS communities).
To be blunt, I urge you not to create a new set of planning guidance or standards, but to instead piggyback any new requirements onto existing FEMA/VDEM standards for hazard mitigation planning. In almost all cases, Virginia communities are assisted by their Planning District Commission and VDEM all-hazards planners in updating their hazard mitigation plans every five years. These partners oversee and facilitate a thorough planning process that ensures public participation at several stages, as well as consistency across the state. Each plan sets out a mitigation action plan for individual communities, and in Virginia those action plans skew heavily toward flood mitigation projects.
According to the 2018 Commonwealth of Virginia Hazard Mitigation Plan (p.6-11), VDEM requires all local hazard mitigation plans include flood maps….and repetitive loss strategy.” Table 3.6-2 indicates flood is a “high risk” hazard in 18 of the state’s 20 local plans, and a “medium risk” hazard in the other 2 local plans. In other words, Virginia’s communities are already examining flood risk and vulnerability in their hazard mitigation planning process in detail. Most plans already inventory critical infrastructure and the risk from flooding to those facilities. Incorporation of several additional guidelines to ensure that the mitigation plan encompasses resiliency standards, as well, is advised versus wholesale creation of a new planning document/process that would essentially repeat existing actions from the mitigation plan.
In fact, the hazard mitigation plan is a perfect vehicle for meeting requirements for a flood resilience plan with just a few minor modifications. The mitigation actions in each plan are prioritized, and each has cost-benefit analysis overview information. The plans could be modified to incorporate standards for resiliency mentioned in the draft guidelines such as:
1. acknowledge climate change and its consequences in the hazard identification and risk analysis (HIRA);
2. identify socioeconomic inequities of flood risk in the HIRA and show how proposed mitigation actions address inequity (your criteria could provide a sample evaluation scale along the same lines as the STAPLEE evaluation criteria, and/or provide metrics for “low-income” flood-prone areas);
3. mitigation actions are prioritized in the plan - instruct that mitigation action prioritization must take into account that green infrastructure/nature-based solutions are more likely to be funded via the Community Flood Preparedness Fund – perhaps a secondary ranking for projects anticipated to be funded under this mechanism could be instituted such that a mitigation action might be Medium Priority for the overall mitigation plan, but High Priority under Community Flood Preparedness Fund;
4. Clearly outline mitigation actions that address vulnerable critical facilities and add options for adaptation, protection or relocation as appropriate (many plans already do this); and,
5. engage multiple community partners to develop regional flood mitigation actions that have impacts throughout a watershed or region.
Furthermore, the hazard mitigation plan review process with VDEM at the helm need not be duplicated for the purposes of a new plan either. The 2018 Commonwealth of Virginia Hazard Mitigation Plan, Section 6.9 State Review of Local Hazard Mitigation Plans, outlines the process as follows:
VDEM mitigation planning staff was involved in the initial development and updates of the local hazard mitigation plans from the grant application through the FEMA final approval. VDEM will not approve or submit a plan to FEMA for review unless it meets all of the FEMA and VDEM local hazard mitigation planning requirements. VDEM regional planners have a 30-day timeline to review local hazard mitigation plans and provide comments, or prepare to submit to FEMA. The PDC submits the plan to VDEM with a request for review and approval, and submittal to FEMA. VDEM provides one electronic copy, one hard copy, and a copy of the plan review tool to FEMA with a letter from the State Coordinator. VDEM requires that all local hazard mitigation plans include flood maps, and that maps be provided for any hazard receiving a ranking of high. VDEM requires a local capability assessment, and that all local hazard mitigation plans include a repetitive loss strategy.
I would also suggest that the final Flood Resilience Plan Guidance, whatever form it may take, be very specific in its requirements and not simply cross reference multiple other documents like the 5 principles of Commonwealth Resilience Planning Principles, Virginia Flood Risk Management Standard, Executive Order 24, ConserveVirginia, and Coastal Resilience Master Planning Framework. Spell out the requirements and don’t make community planners, many of whom wear many other hats at once, track down or have to infer what is intended. Boil it down to the most important elements to add to the hazard mitigation plan (or existing Comprehensive Plan) and I think you’ll create much happier planners throughout the Commonwealth. Merely requiring a community meet the five or six standards and not specifying where those requirements be met (whether it be through hazard mitigation plan, comprehensive plan, or other document) would be ideal in my opinion.
General Editorial Notes:
1. I noted that the Draft Guidelines refer to these plans by two names at different times, both “Local Resilience Plan” and “Flood Preparedness and Resilience Plan”. A Flood Preparedness Plan is a very different document and contains readiness and emergency response features that are not necessarily part of a resilience or mitigation plan.
2. It’s not clear what a “locality-certified floodplain manager” means, nor how one would confirm that an area is subject to recurrent flooding. Not all communities in Virginia with flood problems have an ASFPM-Certified Floodplain Manager on staff. If this is the requirement, that is a big lift for many small towns and rural counties. NFIP data from Virginia DCR can confirm historic flooding.
3. Levees and floodwalls are used as examples of ways to reduce the impact of flooding, but they are not typically viewed as green infrastructure.
4. The Draft Guidelines indicate that “a completed plan will be required before a locality can apply for and receive funding.” If guidance apart from the hazard mitigation plan is prepared, this will need to better explain what is meant by “completed”. Will communities be required to adopt the plan by their governing bodies and how often will it have to be updated? Again, the hazard mitigation planning process already has answers to these questions.
5. On p. 4 of the Draft Guidelines, under “Planning”, the first bullet suggests that a resilience plan could possibly be incorporated into an ordinance. An ordinance is not a logical vehicle for transmitting potential projects and identify funding sources and priorities and all of the hazard information that goes along with these ideas.
6. On p. 5 of the Draft Guidelines, under “Grant Award Criteria”, the 3rd bullet indicates that projects need to be part of the resilience plan or determined to be of significance to the Commonwealth. The word “or” here is significant and suggests that projects need not be in the plan to be eligible. This is not the case for many FEMA grants funding mechanisms. Who and how would projects not in the plans be brought forward and confirmed to be of significance?
7. On. P. 6 of the Draft Guidelines, under “Project Selection”, VDEM is not listed as a consultation partner. In light of the agency’s involvement in other mitigation grant funding mechanisms for the Commonwealth, this seems odd. They review and act on FEMA HMGP and other grant programs on a regular basis.
Thank you for the opportunity to comment.