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Mark Gough’s comment on Federal Emergency Management Agency (FEMA) Proposed Guidelines for Implementing the Federal Flood Risk Management Standard: Docket ID FEMA-2015-0006-0374.

If finalized as proposed, the policy would provide specific guidelines to implement the FFRMS for FEMA Federally Funded Projects, which are actions involving the use of FEMA funds for new construction, substantial improvement, or to address substantial damage to a structure or facility. The policy would select the use of the FFRMS-Freeboard Value Approach to establish the elevation and FFRMS floodplain for FEMA Federally Funded Projects that are non-critical actions. For FEMA Federally Funded Projects that are critical actions, the policy would select the use of the FFRMS-Freeboard Value Approach to establish the minimum FFRMS elevation and floodplain for critical actions. The policy would allow optional use of the FFRMS-Climate-Informed Science Approach to establish the elevation and FFRMS floodplain for critical actions, but only if the elevation established under the FFRMS-Climate-Informed Science Approach is higher than the elevation established under the FFRMS-Freeboard Value Approach. The policy would also encourage early coordination when multiple Federal agencies are jointly engaged in an action to ensure a consistent approach to determine which floodplain determination is applied.

Executive Order 11988, Floodplain Management, as amended and implementing regulations at 44 CFR part 9.

Read Mark’s comment here.