Community Priorities
A too-long post about something I should probably not post about at all. Oy.
I read a post on WizBang recently that blames FEMA for the poor state of the New Orleans flood maps. I don't blame FEMA for the out-of-date flood maps. This is completely out of character for me, I know. Usually I'm all about blaming the federal government for any and all its failings. I don't this time. Mainly because I don't think this is their fault. (And how it hurts me to admit that.) But the explanation for that will take quite a few pixels, so bear with me.
I am a civil engineer. To be specific, I am a water resource engineer, which means I create many hydraulic and hydrologic studies. FEMA regulatory floodways are everywhere; it's fairly difficult to find a non-regulatory stream in the southeastern US. So I've created a good many flood studies for FEMA to modify the current flood data in the National Flood Insurance Program (NFIP).
The NFIP is the regulatory engine that mitigates flood insurance rates, maintains Flood Insurance Rate Maps (FIRM), and updates Flood Insurance Studies (FIS) for participating communities. [Note: I'm going to call FIRMs "flood maps" and FISs "flood studies" for short.] The NFIP relies heavily on community involvement to keep the flood maps and flood studies current. Frankly, the NFIP plan is a good one and, when it is maintained as it is supposed to be maintained, things run fairly smooth.
Here's how it works on my end. When my client develops land on or adjacent to a FEMA regulatory stream, I have to check what impacts that development will have on the stream. I do this by purchasing the FEMA computer model of the stream, the FEMA flood map, and the FEMA flood study that could potentially be impacted by the development. I then update the computer model to reflect the proposed changes of my client.
If the development has no impact on the model, we send a No-Impact Certification to the community (not to FEMA) to inform them that we have looked into the matter and have determined that the flood map will not have to be revised. Communities love No-Impact Certifications, mainly because No-Impact Certifications are cheap and it is fairly expensive to revise flood maps and studies. If the development proposes changes to the flood map and/or flood study, then we have to go through a long FEMA submittal process to revise the flood map and/or flood study. As I wrote earlier, it's expensive.
[At this point, I should probably define "community." A community, as it relates to FEMA, is the body of local government that coordinates with FEMA to keep the flood maps and studies up-to-date. Sometimes it's a county and sometimes it's a city. I don't know how or who decides who has the responsibility. Typically, a city's incorporated areas are on city maps with the remainder belonging to counties.]
Active community involvement in the NFIP is not required. Once a flood map is created, the community is under no obligation to update the flood map to reflect current conditions. And that is the greatest fault in the NFIP: Community involvement. This fault with the communities is two-fold: 1) ignorance and 2) money.
Most people, even the people in the communities responsible for upkeeping the flood maps, do not understand the NFIP; some communities do not have regulations requiring developers to sludge through the NFIP process; and some communities do not participate or force developers to participate even though they have regulations requiring participation. Even if they did enforce their own regulations, most simply don't have the money in the budget to participate. With so many infrastructure problems in the southeast, communities have to prioritize their budget. Often, the NFIP is the first casualty of this prioritization. Communities simply do not want to and/or cannot spend money to keep their flood maps updated. And why should they? It's not required. Most communities are hanging on to their budgets by the skin of their teeth, so anything they don't have to do doesn't get done.
Here in Georgia, it is common to request computer model data from FEMA only to find that the latest model was created in the 1970's with a program that hasn't been used for 20 or more years. Usually, I can't find documentation for the defunct model program, so when I get the copies of microfiche from the original model, I have no idea what the data represents. Even when the current model is in a program currently used, it is quite normal to discover that electronic models are not available. When we're talking about a program such as HEC-2, and old card-type Army Corps step-back water surface profile calculating engine, reconstructing the model from hard-to-read microfiche copies can get extremely expensive. Again, communities don't want to pay for it. And because it's not required, they don't.
So I don't blame FEMA's NFIP for how miserably out-of-date the flood maps are. I blame the communities. It's their job to update their own maps and they haven't been doing it. I haven't worked in Louisiana, but I have worked in Alabama, Georgia, Tennessee, and South Carolina. And in all those states, only one community with which I've worked is actively involved in updating and maintaining good, current flood maps. One other is seriously considering it, but hasn't decided if it's worth the expense. So flood maps all over the southeast are hideously out of date. Considering the huge amount of development that has occurred in Georgia for the past 20 years, most flood maps here are not even close to reflecting current conditions.
Based on what I know of other southeastern states, I can easily believe that New Orleans hasn't updated their flood maps for quite some time. But again, unless New Orleans has some unusual deal with FEMA, FEMA isn't to blame for New Orleans's poor flood maps. That responsibility lies squarely on New Orleans.
I read a post on WizBang recently that blames FEMA for the poor state of the New Orleans flood maps. I don't blame FEMA for the out-of-date flood maps. This is completely out of character for me, I know. Usually I'm all about blaming the federal government for any and all its failings. I don't this time. Mainly because I don't think this is their fault. (And how it hurts me to admit that.) But the explanation for that will take quite a few pixels, so bear with me.
I am a civil engineer. To be specific, I am a water resource engineer, which means I create many hydraulic and hydrologic studies. FEMA regulatory floodways are everywhere; it's fairly difficult to find a non-regulatory stream in the southeastern US. So I've created a good many flood studies for FEMA to modify the current flood data in the National Flood Insurance Program (NFIP).
The NFIP is the regulatory engine that mitigates flood insurance rates, maintains Flood Insurance Rate Maps (FIRM), and updates Flood Insurance Studies (FIS) for participating communities. [Note: I'm going to call FIRMs "flood maps" and FISs "flood studies" for short.] The NFIP relies heavily on community involvement to keep the flood maps and flood studies current. Frankly, the NFIP plan is a good one and, when it is maintained as it is supposed to be maintained, things run fairly smooth.
Here's how it works on my end. When my client develops land on or adjacent to a FEMA regulatory stream, I have to check what impacts that development will have on the stream. I do this by purchasing the FEMA computer model of the stream, the FEMA flood map, and the FEMA flood study that could potentially be impacted by the development. I then update the computer model to reflect the proposed changes of my client.
If the development has no impact on the model, we send a No-Impact Certification to the community (not to FEMA) to inform them that we have looked into the matter and have determined that the flood map will not have to be revised. Communities love No-Impact Certifications, mainly because No-Impact Certifications are cheap and it is fairly expensive to revise flood maps and studies. If the development proposes changes to the flood map and/or flood study, then we have to go through a long FEMA submittal process to revise the flood map and/or flood study. As I wrote earlier, it's expensive.
[At this point, I should probably define "community." A community, as it relates to FEMA, is the body of local government that coordinates with FEMA to keep the flood maps and studies up-to-date. Sometimes it's a county and sometimes it's a city. I don't know how or who decides who has the responsibility. Typically, a city's incorporated areas are on city maps with the remainder belonging to counties.]
Active community involvement in the NFIP is not required. Once a flood map is created, the community is under no obligation to update the flood map to reflect current conditions. And that is the greatest fault in the NFIP: Community involvement. This fault with the communities is two-fold: 1) ignorance and 2) money.
Most people, even the people in the communities responsible for upkeeping the flood maps, do not understand the NFIP; some communities do not have regulations requiring developers to sludge through the NFIP process; and some communities do not participate or force developers to participate even though they have regulations requiring participation. Even if they did enforce their own regulations, most simply don't have the money in the budget to participate. With so many infrastructure problems in the southeast, communities have to prioritize their budget. Often, the NFIP is the first casualty of this prioritization. Communities simply do not want to and/or cannot spend money to keep their flood maps updated. And why should they? It's not required. Most communities are hanging on to their budgets by the skin of their teeth, so anything they don't have to do doesn't get done.
Here in Georgia, it is common to request computer model data from FEMA only to find that the latest model was created in the 1970's with a program that hasn't been used for 20 or more years. Usually, I can't find documentation for the defunct model program, so when I get the copies of microfiche from the original model, I have no idea what the data represents. Even when the current model is in a program currently used, it is quite normal to discover that electronic models are not available. When we're talking about a program such as HEC-2, and old card-type Army Corps step-back water surface profile calculating engine, reconstructing the model from hard-to-read microfiche copies can get extremely expensive. Again, communities don't want to pay for it. And because it's not required, they don't.
So I don't blame FEMA's NFIP for how miserably out-of-date the flood maps are. I blame the communities. It's their job to update their own maps and they haven't been doing it. I haven't worked in Louisiana, but I have worked in Alabama, Georgia, Tennessee, and South Carolina. And in all those states, only one community with which I've worked is actively involved in updating and maintaining good, current flood maps. One other is seriously considering it, but hasn't decided if it's worth the expense. So flood maps all over the southeast are hideously out of date. Considering the huge amount of development that has occurred in Georgia for the past 20 years, most flood maps here are not even close to reflecting current conditions.
Based on what I know of other southeastern states, I can easily believe that New Orleans hasn't updated their flood maps for quite some time. But again, unless New Orleans has some unusual deal with FEMA, FEMA isn't to blame for New Orleans's poor flood maps. That responsibility lies squarely on New Orleans.
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