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Association of State Flood Plain Managers Association of State Flood Plain Managers
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ASFPM Comments on the Connectivity of Streams and Wetlands to Downstream Waters
Monday, February 24, 2014
Feb. 21, 2014

To:

Nancy Stoner  
Acting Assistant Administrator for Water  
U.S. Environmental Protection Agency  
Office of Environmental Information (OEI) Docket  
Mail Code: 28221T  
Docket ID No. EPA-HQ-OA-2013-0582 
1200 Pennsylvania Ave., NW 
Washington, DC 20460 

The Honorable JoEllen Darcy
Assistant Secretary of the Army, Civil Works
Department of the Army, Civil works
108 Army Pentagon
Washington, DC 20310-0108
 
RE: ASFPM Comments on the Connectivity of Streams and Wetlands to Downstream Waters 
 
The Association of State Floodplain Managers supports efforts to update and clarify the rules 
impacting Waters of the US. This rule will be critical in providing direction on how uses of US 
waters can occur while maintaining protection of the public interest. We appreciate the dialogue 
we have had with your offices on this matter. 
 
In this letter we support the importance of a workable definition of “floodplain” as important 
features to inform waters of the US. In developing this definition of the term floodplain, we 
considered the biological and hydrologic role and influences of floodplains to waters, as well as 
assuring that the definition fits in the broader context of other definitions and the rule itself. We 
also considered the need to be sure that the definition provides the certainty needed for 
regulators and the regulated communities alike. We urge that the following definition be used in 
the rule: 
 
“The term floodplain means areas recognized by the federal government, states, local 
governments, or tribes that have been or may be inundated or are susceptible to being 
by inundated by waters from any source when flows or water levels exceed normal 
levels, including the bed and banks of the stream, river, ocean, or other body of water. It 
also includes areas subject to fluvial and other erosion under flood conditions.” 
 
We strongly advise against defining floodplains using FEMA, NFIP, flood insurance delineations 
on FEMA flood maps. Not only are there large sections of the US that the NFIP has not yet 
mapped, but there is significant variability across landscapes of level of detail and granularity of 
study.  
 
ASFPM wants to further support the use of “adjacent waters” in the rule. The definition of 
floodplain integrates well with this and other definitions that will simplify the rule for all 
concerned. 
 
Sincerely, 
 
Chad Berginnis 
Executive Director, Association of State Floodplain Managers 
 
Cc: Jim Pendergast, Acting Director, Wetlands Division, EPA 
Steven L. Stockton, Director of Civil Works, USACE 
Jim Laity, Branch Chief, Natural Resources and Environment, OMB 
Alexandra Dunn, Executive Director, Association of Clean Water Administrators 
Jeanne Christie, Executive Director, Association of State Wetland Managers 




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