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Association of State Flood Plain Managers

Association of State Flood Plain Managers Association of State Flood Plain Managers
Association of State Flood Plain Managers

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ASFPM Requests Member Comments on Corps’ Draft FFRMS Implementation Guidance
Thursday, December 22, 2016

ASFPM Requests Member Comments on Corps’ Draft FFRMS Implementation Guidance

The Corps of Engineers has issued draft that outlines how it will implement the new flood risk management standard to protect federal taxpayer investments in federal actions. The Corps will do this not with rules in the Federal Register, but by amending internal guidance they have used for years to implement the old EO 11988. They have put the draft EC out for comments, which are due to USACE on or before Jan. 30, 2017.

ASFPM is asking all of you who wish to provide feedback for consideration into ASFPM’s comments to please submit to either Executive Director Chad Berginnis (cberginnis@floods.org) or Director Emeritus Larry Larson (Larry@floods.org) by Jan. 25. If you can, we urge you to submit your own comments to the Corps as well. The more the better!

Here is link to CFR with summary and other data on Engineering Circular process.

Unlike FEMA and HUD, which have opted to use the freeboard approach to establish the elevation and horizontal extent of the FFRMS floodplain, USASE indicates on page 8 of the draft EC, “All Corps actions subject to the FFRMS will utilize the [Climate-Informed Science Approach], unless compelling justification for using one of the other approaches is developed and documented”. It goes on to say that decision must be approved up the line.

The draft EC indicates CISA will be calculated using Appendix H of the guidelines issued Oct. 8, 2015 for use by all federal agencies. The guidelines discuss use of SLR estimates in coastal areas, and the need to determine new hydrology in riverine areas taking into account projected increases in rainfall and land use changes. It acknowledges FEMA is not yet mapping future conditions, including coastal erosion as required by BW-12, and it provides links to a variety of resources to assist agencies in making CISA determinations and promotes determining local conditions (or use of local information where appropriate). Appendix H starts on page 57 and goes to end of doc. It’s good on coastal, but weaker on the process to use to determine CISA in riverine areas.

BTW, all of this info in on FFRMS page of our web site, which has a link on front page. We will update that web page with the Corps draft EC info. Learn more here on ASFPM’s FFRMS page.






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