With the intent to simplify processes and introduce new initiatives that will help communities receive additional National Flood Insurance Plan (NFIP) discounts, the Community Rating System (CRS) has released an Addendum to the 2017 CRS Coordinator's Manual, effective January 1, 2021. This Addendum is meant to bridge the gap between the 2017 CRS Manual (which expired March 31, 2020) and the more extensive update that will likely be required as the Federal Emergency Management Agency (FEMA) continues to finalize improvements to the NFIP. While many of the changes involve only minor updates and clarifications there are several that are more outstanding in scope and will have an impact on all communities that participate in the CRS.
The more substantial changes center around Activity 310 and are likely to cause the most growing pains and questions, but will likely reduce local compliance errors overall. Currently, the CRS conducts courtesy reviews of Elevation Certificates (ECs) during recertification visits in preparation for verification visits, where ECs are checked for correctness as a Class 9 prerequisite and for 310 credit. Instead of these two types of reviews, will now be only one annual evaluation, occurring on your recertification date. This basically combines the two reviews into one event, which is intended to reduce the amount of time spent by both parties. The annual evaluation is also meant to catch reporting errors earlier, as opposed to finding them every three to five years, and allow for more timely and efficient corrections.
The Class 9 prerequisite of 90% accuracy will still be required but now there will only be two chances to achieve that rate instead of three. This means that floodplain managers will need to be more diligent in catching EC errors. But that isn’t the only change happening. ECs will now become part of the newly created Construction Certificate Management Procedures (CCMP).
CRS section 311 has been moved to 301 and Element EC has been renamed CCMP, which stands for Construction Certificate Management Procedures. This revision is to expand the element to include all certificates required for new construction and substantial improvement (SI), not just ECs, and also address when those certificates are required. It will serve as the main Class 9 prerequisite. The CCMP will also need to detail how all certificates, not just ECs, are to be handled and must include certain steps. Namely, identifying all certificates required beyond ECs, who collects and reviews the certificates, how they will be corrected and maintained, and how the documents will be made available to the public.
The CCMP will also greatly simplify the scoring process as ECs will no longer be reviewed for scoring points in the CRS, simply having the CCMP will get you the full thirty-eight points (ECPO and ECPR points will not be affected). This is not meant to be a set-it-and-forget-it plan. You should consider incorporating a review process every three to five years, or at least with each new release of the CRS Coordinator's Manual, to ensure your procedures stay up to date.
The idea behind the CCMP is to help communities create a system with long-lasting benefits rather than just processing paperwork. Creating these guidelines is also an excellent opportunity to engage with residents about the permitting process and open discussion on flood risk and mitigation activities. As accuracy and efficient document handling are key pieces of the CCMP, it would be a great time to take steps to update your document filing and storage process for the future as well. Many of our community partners are looking forward to utilizing Forerunner to address this need. An important feature in our floodplain management platform is Elevation Certificate data management and extraction. If you’d like to chat about how we might help your floodplain program, or if you would like advice on how to create more robust management procedures, please don’t hesitate to reach out!
There are a few possible scenarios of how this can affect your reporting but, to begin with, it is important to note that everything will happen on your recertification date. The CRS will notify you forty-five days prior with what you will be required to have ready and the most significant action you can take is to have your CCMP in place and get your 38 points. If you do not have a CCMP, you will not be awarded any points; it is an all-or-nothing scenario. The CRS website has templates to guide you through that process to make it easier for you to be ready.
All communities will need to submit ECs as part of the overall CCMP but, if 2021 happens to be your regularly scheduled recertification year, you have the easiest transition and will only need to create your CCMP. If you are in an open cycle, just closed, or were scheduled to cycle in 2021, it really won’t be that much more difficult, you’re just submitting the paperwork on your recertification date instead of at the end of cycle or resubmitting ECs that were verified previously. The important thing for those communities to remember is there’s only two chances to achieve a passing grade on your ECs so take that time to review, know what an accurate EC should look like, and get corrections as needed before the review happens.
The creation of the CCMP allows communities to meet their Class 9 prerequisites more easily to stay in the program. Setting one annual review allows communities to prepare consistently year over year, become more efficient with document processing, and make it easier for residents to understand and take advantage of credits they are eligible to receive. The increased review process will also allow managers to catch non-compliance and resolve issues in a more timely manner. These steps will hopefully improve insurance ratings and NFIP compliance and set all communities up for greater savings going forward.
The burden of accuracy will not just be the responsibility of the communities in the program. The CRS will also be taking on a greater workload by reviewing all ECs per community, up to three hundred (300), a substantial increase over the seventy (70) that were previously reviewed.
Compared to the changes under Activity 310, the introduction of a new freeboard requirement for Class 8s (or better) is relatively straightforward. The Addendum implements a freeboard requirement of at least one foot that will apply throughout the Special Flood Hazard Zone (SFHA) where base flood elevations (BFEs) have been determined, but will exclude designated open space areas. This is to include equipment and mechanical items for all residential buildings—floodproofing will not count—and manufactured homes in all numbered zones.
A one-foot freeboard over BFE (BFE+1) helps to reduce property damage and insurance premiums and many communities have already been adopting this requirement. The CRS took notice and this prerequisite change will reward communities already making the effort and encourage managers to consider this option for their area as well.
If you want to take advantage of this new prerequisite as an opportunity to improve a class then you will need to initiate an ordinance change before your first CRS Verification visit after January 1, 2021, or by the release of the next CRS Manual. Because of the financial burden these changes may levy, targeted community outreach and resident education on how this might affect their properties and premiums should be heavily considered.
The updates to Activity 510 revolve around recognizing and protecting natural floodplain functions (NFP) and have expanded to include the species that inhabit those areas by providing additional credit for having a Floodplain Species Assessment in your plan.
Additional new credits can be obtained by preparing a substantial damage management plan (SDP) for use in assessing damage after hazard events. The SDP points awarded in Section 512.c were added to encourage communities to make Substantial Damage preparations before a disaster occurs – so that deploying resources will be easier and less confusing. If you’re new to Substantial Improvement and Substantial Damage (SI/SD), you might want to check out our SI/SD Guide and Webinar Series to learn more. Points awarded for this element are broken down into three tiers: 1. Pre-flood efforts, 2. Pre-populating using substantial damage estimator, 3. Considering mitigation alternatives. A key task in developing the plan is establishing a SI/SD database for recording improvement and damages. If you’re not sure where to start, you might be interested in learning more about Forerunner’s SI/SD features.
Credits for the flood insurance coverage improvement plan (CP) and technical assistance on flood insurance (TA) have increased thirty and thirty-five points, respectively, but the biggest change comes with the addition of three new credit opportunities. Designed to increase public knowledge regarding flood risk and promote flood insurance led to credits for making flood insurance brochures (FIB) available to the public and holding community flood insurance meetings (FIM). Credit can also be received when insurance agents attend state-required continuing education (SCE) classes on flood insurance. Education is a recurring theme, but “knowing is half the battle,” right?
Updating this element addresses how the impact adjustment of a community’s watershed will now be handled. Points will be based only on the portion of the watershed that is in your community and that you regulate, and will no longer include portions outside your community. While this will not be a major change for some communities, it could be a welcome change for others.
Beyond updating workflows and gaining credits, the release of this Addendum provides an opening for floodplain managers to meaningfully engage and educate residents about local flooding conditions. We're following conversations about CRS changes carefully – as the addendum and the new manual evolve, we’ll be sure to add additional information here. In the meantime, if you’d like to chat about our learnings, or to learn more about our product offering, please feel free to reach out!