Evaluating the effectiveness of floodplain management techniques and community programs proceedings of a seminar conducted April 30-May 1, 1984

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COASTAL ZONE
INFORMATION CENTER

Natural Hazards Research
and Applications
Information Center

GB
562
.E9
1985

Proceedings of a Seminar

EVALUATING THE EFFECTIVENESS OF

FLOODPLAIN MANAGEMENT TECHNIQUES AND

COMMUNITY PROGRAMS

COASTAL ZONE
INFORMATION CENTER

Special Publication
10

Conducted April 30 -May 1, 1984
in Washington, DC

The Tennessee valley Authority

In cooperation with

The Interagency Task Force on Floodplain Management

1985 Property of CSC LIBRARY

U.S. DEPARTMENT OF COMMERCE NOAA
COASTAL SERVICES CENTER
2234 SOUTH HOBSON AVENUE
CHARLESTON, SC 29405-2413

FOREWORD

is elevation on fill a more reliable and cost-effective long-term

approach to mitigating flood damages in flood fringe areas than

structural floodproofing or elevation on pilings? What are the possi-

bilities for expanded use of local flood warning systems, self-help

activities, and acquisition/relocation,programs? Are communities

adequately enforcing protection elevations and flood hazard mitigation

..measures or are they issuing variances and amendments whenever political

pressures build? These are some of the unanswered or only partially

answered questions facing flood loss reduction policy makers.

Despite extensive efforts at federal,.state, and local levels to

implement structural and nons.tructural floodplain loss reduction

.measures in the last decade, there has been little "on the ground"

evaluation of the effectiveness of different approaches and programs,

particularly duringactual flood conditions.

This seminar, "Evaluating the Effectiveness of Floodplain

Management Techniques and Community Programs," was held in Washington,

DC, April 30 and May 1, 1984. Sponsored by the Tennessee Valley

Authority with the cooperation of the Interagency Floodplain Management

Task Force, the goal of the seminar was to examine existing and

alternative cooperative approaches for evaluating and monitoring

floodplain management techniques and community programs. The seminar

was intended to assess the "state of knowledge" on this important topic

and to suggest some priorities for further interagency research and

action.

Speakers, panelists, and other participants in the seminar were

selected because of their practical experience in monitoring and/or

evaluating local programs. They included university researchers,

federal agency staff, state and local government employees, and private

consultants who had investigated the feasibility and effectiveness of

various techniques or community programs.

This report is a collection of three products. Part I presents a

brief overview of issues* Parts II and III are issue papers prepared

prior to the seminar by Jacquelyn Monday with input from ion Kusler,

summarizing the state of knowledge concerning evaluation of the

effectiveness of nonstructural floodplain management techniques and

community programs. The issue papers were distributed to all speakers

and participants prior to the seminar to stimulate discussion. Part IV

contains papers presented by speakers and panelists in the seminar

addressing specific issues. Part V,.the conclusions and

recommendations, and the executive summary were prepared by ion Kusler

and Jacquelyn Monday and based upon the issue papers, the papers

presented at the seminar, and follow-up discussions with selected

speakers and panelists.

ACKNOWLEDGEMENTS

The opinions expressed herein are those of the authors and do not

necessarily represent those of the Tennessee valley Authority, the

Interagency Task Force on Floodplain Management or the various agencies

at the seminar. Funding support from the Tennessee Valley Authority is

gratefully a.cknowledged along with the helpful comments and assistance

of Jim Wright and Ann McManamon. Special thanks is also due to the Task

Force members, speakers and panelists for their help.

Jon Kusler
Seminar Director

Jacquelyn Monday
seminar Coordinator

TABLE OF CONTENTS

EXECUTIVE SUMMARY ..................... ..... viii

Part I SUMMARY AND OVERVIEW ..................... 1

Part II EVALUATING THE EFFECTIVENESS OF NONSTRUCTURAL
FLOODPLAIN MANAGEMENT TECHNIQUES IN REDUCING
FLOOD LOSSES--An Issue Paper.,.,**.* ..... **** ......... 7

Part III MONITORING THE EFFECTIVENESS OF COMMUNITY
FLOODPLAIN MANAGEMENT PROGRAMS--An Issue Paper .......... o.35

Part IV SPEAKERS' PAPERS--Effectiveness of Individual Techniques..61

Cost-Effectiveness of Local.Flood Warning Systems
Curtis B. Barrett, National Weather Service ............. 62

Self-Help Flood Damage Reduction in the Susquehanna River
Basin
Stewart K. Wright, Susquehanna River Basin Commission ... 65

Cost-Effectiveness of Elevating and Floodproofing New
Structures
Larry Flanagan, U.S. Army Corps.of Engineers ........ * ... 67

Floodproofing Buildings in Illinois
Frence Wetmore, Illinois Division of Water Resources .... 70

Cost-Effectiveness Considerations of Acquisition/Relocation
in Floodplain Management: The Soldiers Grove, Wisconsin
Experience
Thomas Hirsch,
Wisconsin Department of Natural Resources ....... oe ...... 74

Assessment of Annual funding Need for Purchase of Flood-
Damaged Property Under Section 1362
Federal Emergency Management Agency ..................... 77

Part IV SPEAKERS' PAPERS--Monitoring Community Programs ............ 89
(cont'd)
Monitoring Options: Questionnaires, Telephone and Onsite
Surveys
Raymond J. Burby, University of North Carolina ....... 0..90

Wisconsin's Monitoring of Community Programs
LuAnne Hansen and Thomas Hirsch,
Wisconsin Department of Natural Resources ............... 94

Monitoring Floodplain Management Techniques and Community
Programs
Mary Fran Myers, Illinois Division of Water Resources ... 97

monitoring Local Floodplain Regulations in Illinois
French Wetmore, Illinois Division of Water Resources ... 101

monitoring Local Floodplain Management
Marguerite Whilden,
Maryland Department of Natural Resources ..... 4-00-0.1.06

.Monitoring Local Government NFIP Administration
Rick Mayson, FEMA Region IV ...... 0.110

FEMA Region VII Experience with Community Assistance and
Program Evaluation
Patricia K. Stahlschmidt, FEMA... ................. 116

The CAPE Process in FEMA Region III
Walter Pierson, FEMA Region III .............. ... *.122

Part V: RECOMMENDATIONS ......................... ............. 125

vii

EXECUTIVE SUMMARY

Conclusions

very little "on-the-ground" study has been made in the last two

decades of the effectiveness, particularly in an actual flood, of the

various structural and nonstructural floodplain management techniques

now in place. This is in sharp contrast with the considerable amount of

sociological, geographical, political science, legal, and other policy-

related research that has been conducted on floods. In other words,

efforts have been made to diagnose the flood-prone patient's ills,

suggest alternative medicines, study why or why not particular pills and

surgery are selected, and monitor the patient's attitudes, but very

little has been done to determine whether or not the various treatments

are curing the disease.

The need for follow-up testing of approaches is essential as a

basis for the establishment of flood insurance rates that reflect actual

risk and the selection of cost-effective flood loss reduction techniques

appropriate to particular contexts. The opportunities for follow-up

have improved dramatically in the last decade due to, on one hand, the

widespread adoption of nonstructural elevation and floodproofing, and,

on the other, improved data gathering and analysis capability at the

federal and state levels through NFIP community biannual reports, flood

insurance policies, flood insurance claims, disaster assistance claims,

post-disaster interagency team reports, environmental impact statements,

sub-section 406 plans, and federal, state, and community program evalua-

tion visits. There is considerable potential for combining this infor-

mation with selected onsite surveys both before and after a flood. A

careful setting of priorities for data gathering, coordination of data

viii

PART I: SUMMARY AND OVERVIEW

Part I is based upon.the issue papers, workshop presentations and follow-up
discussions with Interagency Task Force members.

Need for Monitoring and Evaluation

Given the adoption of floodplain regulatory programs by
17,000 local governments since 1970 and the widespread
application of nonstructural flood hazard loss techniques to
date (an estimated 100,000-200,000 new structures each year),
surprisingly little hard data have been developed about the
precise causes of flood losses (e.g., flood stage, velocity,
debris, erosion), the types of buildings and uses suffering
direct and indirect losses, or the effectiveness of various
mitigation techniques and construction designs under particular
conditions. This lack of monitoring and evaluation is not
confined to community programs and nonstructural approaches.
Cost-benefit evaluations often have been carried out by federal
agencies before construction of dams'and levees, but rarely has
there been-detailed follow-up assessments to determine
effectiveness of the structures in reducing losses.

How serious is this lack of "on-the-ground" testing or
verification of effectiveness? In some instances, lack of hard
data on effectiveness is seriously hindering policy making and
mitigation. It places limitations upon:

(1) The selection of the most effective.hazard mitigation
techniques by individual landowners,- communities,
states and federal agencies;

(2) Establishment of performance standards for new use.s
and retrofitting existing structures by local
governments, the states, and FEMA;

(3) Flood insurance rate-setting that'reflect actual
losses for specific types of uses;

(4) FEMA's enforcement actions for the National Flood
Insurance Program including community suspension and
subrogation law suits;

(5) Training and education and technical assistance
programs at all levels of government;

(6) Congressional policy setting on particular structural
and nonstructural techniques and the authorization of
and appropriations for particular projects.

What information gaps and unanswered questions are limiting
such efforts? Examples include: *

(1) Is structural floodproofing of particular types (e.g.,
waterproofing of a commercial structure by installing

Note that this is only a preliminary list.

water-tight walls and closures) actually effective
when a flood occurs? What are the expected losses in
comparison with other approaches? There is some
evidence that waterproofing is rarely effective for
flooding more than a few hours in duration without
back-up sump pumps.and that the incidence of damages
from a full range of floods may be much greater than
for elevation on concrete pilings or fill. If so, how
should this be reflected in regulatory guidelines and
insurance rates?

(2) Does elevation on fill in the flood fringe actually
provide a higher safety factor than elevation on
wooden pilings or structural floodproofing? If so,
how should this be reflected in regulations and
insurance rates?

(3) What has been the actual performance of various
structural flood damage reduction measures?

(4) How extensive are "unique" hazards such as alluvial
fan zones, mudfloods, lake flooding and coastal
erosion in terms of number of structures at risk,
growth rates, and losses per structure? How effective
(or ineffective) are current management approaches for
other areas when applied to these problems?

(5) What percentage of flood losses are, in fact, storm
water management losses from sheet flows, channel.
overflows, and flooding along small unmapped
floodplains? How effective are existing criteria and
designs for stormwater management?

(6) Has the NFIP actually reduced disaster payments for
particular areas? If so, to what extent? @Are there
duplications in benefits?

(7) Are communities actually enforcing the standards of
the NFIP particularly for new buildings or for
retrofit@ing after a disaster? If not, what are the
implications of this for future flood losses? If so,
what losses can nevertheless be expected due to the
limitations of the techniques?

(8) Are local responsibilities for maintenance of
structural control works being carried out?

(9) What are the implications of sea*level rise and
subsidence (assuming various rates) on the
rati-o,s for sea walls, groins, and beach
nourishment?

(10) What types of communities have the most severe flood
hazards in terms of threats to life and to property so
as to qualify them.for flood warning systems,
evacuation planning, and technical assistance?

Overall, there has been limited on the ground testing or
modelling of floodplain management techniques to determine (a)
effectiveness in actually reducing losses in flood conditions
and (b) cost-effectiveness.

Measures of Effectiveness.

"Effectiveness" can be measured by several yardsticks.
Some measures applied to date include:

(1) Has a landowner agreed to apply a.particular hazard
mitigation technique consistent with certain standards
and criteria? At the community, state or local level,
has a.unit of government adopted a program regulating
land use, insuring property, or otherwise designed to
reduce flood losses? During the early states of the
NFIP communities were allowed to enter the emergency
program based upon a statement of community intent and
the adoption of regulations (in resolution or
ordinance form). In a sense, this was an initial
determination of "effectiveness" and compliance.
Intent to adopt or even adoption of an effort or
program itself does not, of course, guarantee that
flood losse's will be reduced.

(2) Has the landowner or unit of government actually
applied the technique or implemented the program so
that the flood 'hazard mitigation measures are
designed, constructed, and maintained consistent with
agreed-upon standards? Implementation of required
regulations is important in determining community and
landowner compliance with state and federal
regulations and guidelines for the purposes of
enforcement actions, payment of insurance claims, and
initiation of subrogation suits. Consideration of on-
the-ground implementation of particular standards is
an important additional step in evaluating
effectiveness but it will not insure reduction in
losses unless the techniques are technically sound.
For example, community adoption and enforcement of
floodplain regulations allowing buildings on
unreinforced pilings in an alluvial fan may comply
with federal criteria but may not appreciably reduce
flood losses from debris-laden flows moving at 15 to
30 feet per second.

(3) Has the landowner or unit o f government adopted and
implemented a mitigation approach that will actually
achieve certain flood loss reduction levels? Actual

effectiveness in flood loss reduction is, of course, difficult
to determine until actual flooding occurs. Efforts to a@�sess
reduction in losses are also complicated by difficulties in
projecting what might have occurred in the absence of the
technique or program.
lip
(4) I's the adopted mitigation technique cost effective
from a narrow flood loss reduction perspective or
broader landowner, community or state cost/benefit
perspective? Effectiveness in flood loss reduction
does not in itself indicate cost effectiveness in a
broader sense. Broader cost effectiveness considers
the full range of benefits of the technique, (e.g.,
pollution control) and costs (e.g., foregone
opportunities costs) and relative cost effectiveness
in,comparison with other techniques.

Some efforts, discussed in the materials what follow, have
been made to assess effectiveness both narrowly and broadly.

Impediments to Evaluation

Academic research and agency studies to date have rarely
addressed the question: "How are techniques actually working
in-loss reduction?" This seems a bit curious since hundreds of
geographical, sociological, psychological and political science
oriented projects have been funded to examine other aspects of.
hazard response and preparedness. Such studies have led to
improved understanding of landowner attitudes, community and
individual response in times of disaster, and the working of
government. But little empirical data have been generated
about the actual long-term performance of various flood hazard
mitigation techniques in reducing losses. Why?

Gathering of such data can be time-consuming and expensive
since field studies are needed. It is difficult to predict
when and where floods will occur,complicating the formulation
and conduct of research projects. Traditionally, the National
Science Foundation and other funding organizations have not
emphasized ."applied research" in their programs (although some
certainly has been funded). Applied research has been
primarily considered to be the task of the various regulatory
and management agencies. App,lied research that critically
examines the agencies' own programs is rarely undertaken. In
part, the problem is that regulatory and management agencies
are often understaffed and underfunded. Equally important,
ao6ncies have a vested interest in the results of research.
Will an agency faced with budget review and political pressures
critically examine or publicly acknowledge that a dam, levee,
structural floodproofing measure or flood warning system
designed by the agency will not or is not functioning as
represented? Sometimes agencies have discouraged critical
evaluations or have disputed results that have been generated
by others.

New Opportunities and Approaches for Determining Effectivenes

Fifteen years ago, only 400 communities had adopted
floodplain regulations, and most of those were located in the
Tennessee Valley. There was little quantified flood hazard
mapping (e.g., the 100-year. flood). Between 1970-1974 over
16,000 communities "adopted floodplain regulations. Quantified
flood data, including the 100-year flood elevation,were
developed for over 8,000 communities.

As a result of this progress, at least 5,000-6,000
communities now have at least ten years of experience
(1974-1984) with various nonstructural approaches that are
consistent with overall state and federal standards. Floods
are occurring each year in some of these communities. As they
occur, they provide opportunities to determine the
effectiveness of a variety of techniques. The potential for
such analysis is enhanced by the gathering and computerization
of certain types of data:

(1) Flood insurance policy data;

(2) Flood insurance claim data;

(3) Disaster assistance claim data; and

(4) Community annual and biannual report data.

In addition, information is potentially available from
federal post disaster teams that have been sent into the field
after federally declared flood disasters since 1979 to
determine federal mitigation potential. Reports are filed by
each team. States and communities are also undertaking post
disaster mitigation surveys pursuant to Section 406 of the
Disaster Relief Act of 1974 in order to qualify for disaster
assistance.

These fact ors and existing data bases offer the potential
for much improved determination of the effectiveness of
community programs and individual floodplain management
techniques.

.6.

PART II: EVALUATING

THE EFFECTIVENESS OF NONSTRUCTURAL

FLOODPLAIN MANAGEMENT TECHNIQUES

IN REDUCING FLOOD LOSSES AN ISSUE PAPER

This-issue paper is designed to stimulate discussion at the Monitoring and
Effectiveness Seminar April 30 and May 1, 1984. Because of this, the
issues presented herein are left unresolved and the ongoing efforts subject
to discussion at the seminar have been described only briefly.

CONTENTS

Page

Questions for Discussion at seminar . . . . . . . . . . . . . . . . . 9

The Need for Effectiveness Evaluation . ... . . . . . . . . . . . . . 9

Efforts to Evaluate.Effectiveness . . . . . . . . . . . . . . . . . . 10

Flood Warning Systems . . . . . . . . . . . . . . . . . . . . . . . 10

Elevating and Floodproofing Existing Structures . . . . . . . . . . 15

Elevating and Floodproofing New Structures . . . . . . . . . . . . 19

Acquisition and Relocation . . . . . . . . . . . . . . . . . . . . 22

Problems with Evaluating Individual Techniques . . . ... . . . . . . . 26

Variable Situations . . . . . . . . . . . . . . . . . . . . . . . . 26

Estimating Counterfactual Components . . . . . . . . . . . . . . . 29

Measurement of Savings . . . . . . . . . . . . . . . . . . . . . . 29

Systematic Methods . . . . . . . . . . . . . . .. . . . . . . . . . 29

Lab Research .* . . . . .. . . . . . . . . . . . . . . ... . . . . . 29

Post-flood Assessments . . . . . . . . . . . . . . . . . . . . . . 29

Funding . . . . . . . . . . . . . . . . . . . . . ... . . . . . . . 30

Options for Improved Effectiveness Evaluation . . . . . . . . . . . . 30

Bibliography . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Questions for Discussion at Seminar

What has been concluded about the cost effectiveness of particular types
of floodplain management techniques? What factors influence costs and
benefits in a particular circumstance? What approaches appear most
attractive from a cost/benefit perspective? How do the results of one
study compare with those of another?

How was the cost effectiveness determined (i.e., method)? What problems
(if any) were encountered in. determining cost effectiveness? What
approaches are applicable in other situations?

Given limited dollars, how could TVA, the Federal Emergency Management
Agency (FEMA), or other agencies set up a system for monitoring the cost
effectiveness of floodproofing systems?

The Need for Effectiveness Evaluation

Damages from riverine and coastal flooding can be reduced by
flood control structures, floodplain management and zoning,
building codes and flood proofing, stormwater management, coastal
zone management, flood forecasting, evacuation and relocation.
In addition, the costs of risk bearing of flood losses can be
reduced or shifted by flood hazard insurance and post-disaster
relief policies . . .

What is needed, however, is a series of benefit cost studies
to justify the measures . . .

There is an immediate need to make an economic evaluation of
the National Flood Insurance Program (NFIP) . . . Evidence on the
benefits and costs of (floodplain land use control] policies has
not been developed . . . The economic methodology exists but the
benefits and costs of flood forecasting and flood warning systems
are not known. . . How else can we determine whether the costs of
mitigation are worth incurring? (Milliman, 1983, pp 100-102)

Both the legislative and executive branches of government
should be aware ofthe need for considering solutions other than
the traditional ones for reducing flood damage . . . . One of the
first requirements is to assure the study of alternatives to
structural measures during the process of flood control or flood
prevention surveys. . .

Survey reports should present, along with other information,
the results of studies of --

A(a) -The -effect an floodplain'use of alternative measures
such as regulation, improved forecasting, flood proof-
ing, and public acquisition;

(b). Nearby areas suitable for development as an alternative
to floodplain development;

(d) Combinations of measures and degrees of protection
which maximize the net benefits. (Task Force on Federal
Flood Control Policy, 1966, p. 40)

Achievement of. the goals of floodplain management requires
analysis of all alternative plans prior to selecting a course of
action There is a need to apply accepted techniques of
analysis and evaluation consistently, regardless of the applica-
ble legislation or level of jurisdiction involved. . . . These
techniques should provide comparability for investment decisions
and a full display of all alternative strategies and tools within
the conceptual framework of floodplain management. (U.S. Water
Resources Council, 1979, p. VII-13)

Efforts to Evaluate Effectiveness

Flood Warning Systems

The National Weather Service has in effect a flood watch and flood
warning system for all coastal and inland waters. Modern technology has
greatly enhanced the capability of issuing timely and accurate warnings
that can save lives and reduce damages. This is particularly true for
localities--especially those prone to flash floods--that have developed
specific, supplemental warning systems. Already over 800 minicomputer
warning systems are in use in the United States. The effectiveness of such
systems depends, in large part, on proper responses by emergency operations
personnel and the public in disseminating the warning, evacuating, and
moving or securing property.

An evaluation of -the effectiveness of a flood warning system can be
made by balancing the costs of establishing and maintaining the system
against the benefits derived thereby. Costs are fairly easy to pinpoint.
The table on the next page shows the range of equipment, procedures and
accompanying expenses for five warning systems.

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The benefits of a system are harder to specify. Owen and Wendell
(1981) have classified potential benefits.into three categories:

1. Safety, e.g., opportunity to evacuate and assist others.to do
so and to deploy emergency personnel, time to institute
traffic controls and to institute emergency measures to avoid
fire and explosion;

2. Reduction of property damage, e.g., movement of autos,
furniture, livestock, etc., protection of fixed equipment by
disconnection or wrapping, and protection of structures by
sandbagging or intentional flooding of basements; and

3. Reduction of other losses, e.g., faster return to normal
business operations, elimination of precautions found later
to be unnecessary, reduced relief costs, and reduced risk of
liability for injury or death to patrons, students, patients
or employees.

Not all of these benefits can be quantified, but the result of estimat-
ing the dollar value of some of them and weighing that against the costs
can yield an approximation of the effectiveness or worth of the system.
Local officials were asked to do just that in one study of flood warning
systems (Owen and Wendell, 1981). In New Braunfels, Texas, they estimated
that moving city equipment after receipt of a warning would reduce damages
by about $1 million, almost half of the public losses in a previous flood.
Overall, advance warning is expected to enable a 25% reduction in total
damages (1981, p. A-16). Damages at Vandenburg Air Force Base in Califor-
nia due to a January 1969 flood were about $3 million. Officials estimate
that early warnings will cut future losses from a flood of that magnitude
by one-half (1981, p. A-27). - I

In Wise County, Virginia, 350 automobiles were saved by moving them to
higher ground after a flood warning, and at least $25,000 were saved over
one weekend by not overreacting to a potential flooding situation (1981, p.
A-34). A 10-hour advance warning in Coeburn, Virginia, resulted in millions
of dollars of savings, according to local officials, when fire and communica-
tion equipment, vehicles, graders and backhoes were moved, and the water
and sewer system pumps.were shut down for their protection (1981, p. A-35).
Similiar actions by city officials in Appalachia, Virginia, saved $200,000
to $300,000 (1981, p. A-36).

In the case of real property, there is an accepted procedure for eval-
uating the benefits from reductions in flood losses. The same procedure is
applicable to an evaluation of damages that have been avoided or reduced
due to receipt of a warning, except that the concept of a specific level of
protection is replaced as a variable by the lead time of the warnings and
the degree of the response to them. The procedure, outlined by Day and Lee
(1976) and applied to warnings by Owen and Wendell (1981),* consists of
constructing stage-damage curves for different categories of property and
summing the damages prevented with various lead times and responses (see
diagram on next page).

Input
Property Assessment
Data on the Flood Plain
(Structure by structure)

A specific strVctur,

(Jae&, stories,
no. %milies,
furo.x hing, ground elevati
t
y c
p ;P,Iass.. first flood ab
k: c the ground
up

classification

L, erc, it. . i de It iI
' &Istri::l Trailer
Indu Atitowitibile

Input:
Flood stage recul-r-ence
Llass Coding Automobile interval table@ fur e-ach
clabs or one of several s@ciiun of Ihe flood plain
residential classes or 1r'a1I4'r'
Iau.es

1. Cla.i, -ding
Flood st aCe . bove the ground vs.
r, current in tervaI
FI ,.d s t aor a buve first flour
v- -urrence interval

Input:.
Stage;d:m:ge tables
An appropriate stage- for c n i tons
damage table such .. NW, LWT.
MPE. etc.

AdditiucnaJsconstraints and
Adjustm In It such as communi
and organization

S; recurre7ce interval under
co &g7i:n
di tif II., ItIT, MPE, @Lc.

Expected Annual 0:m" ge Aft
(%W, LWT, MPE, et .1

So I
.=:ry I.:b
ry r ii.it.

CO@TUTATION PROCEDURES

a
(Owen nd Wendell, 1981)

TOTAL DAMAGE
ONE STOR-1. NO BASEMENT STRUCTURE

COST

Percentage of
structure Value

Uj
LU

AcQuieltion of
to
Structure a site

LL.
0
Uj

W Z Remove structure
Uj
U to now site
W 5 5
x fL
4- -4

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I F H F lomporary
0 Closures
0 5 to 15 20 25 30
EVENT AT FIRST FLOOR (EXCEEDANCE INTERVAL,YEARS)

(Johnson and Davis, 1982)

The Susquehanna River Basin Commission reports that $3.5 million in
losses have been avoided in the Swartara Creek Basin since a flood warning
system was established there in. 1976 (Bresenhan, -no date). The State of
Arizona uses satellite telemetry for flood forecasting. About $1 million
was spent to install the system and state officials believe the system pays
for itself whenever 50 mobile homes or 200 automobiles are moved out of the
path of a flood (Bond, no date).

Elevating and Floodproofing Existing Structures

Raising residential or small commercial structures on fill or on open
works such as walls, columns or piers is a common nonstructural technique
for reducing losses both in coastal and riverine flood hazard areas. There
are a number of options available for both "dry floodproofing" -- keeping
floodwaters out of a structure -- and "wet floodproofing" -- intentionally
allowing water to enter the basement or first floor to counteract the
pressure of floodwaters on-the exterior.

The costs of floodproofing or elevating an existing structure vary
widely, and the cost effectiveness can vary even more, since it depends on
the additional variables of the flood event. A number of different approach-
es have been taken to attempt to measure the costs and/or benefits of
floodproofing and elevating buildings.

The results of one analysis by the Corps of Engineers are illustrated
in the figure on the next page. The cost of elevation and other non-struc-
tural measures is shown" as a percentage of the value of the structure.
According to these data, elevating a structure is economical only if it is
subject 'to high damages, in this. case about the 15-year flood at the first
floor (U.S. Army Corps of Engineers, 1978). This general conclusion was
supported- by the results of a study of the feasibility of floodproofing
residences in Logan, Ohio. There it was determined that the stage-frequency
relationship has a profound impact on the economic feasibility of raising a
structure. The pertinent aspect of the stage-frequency relationship is the
so-called flood hazard factor or FHF -- the difference in elevations
between the 100-year and 10-year floods, expressed in tenths of a foot. In
this analysis the benefit/cost ration improved as.the FHF declined, suggest-
ing that elevation is economically feasible when the FHF for the structure
is low (McCoy, 1976).

Another study performed cost estimates for five non-structural measures
for four sites in the Baltimore area. The f igure shows a sample of the
costs estimated for elevating a one-story house with a stone foundation to
each of four heights. The table on the page following that illustrates how
the costs of the various techniques can be compared to each other. No
f inal conclusion was made with regard to the general advisability of
pursuing one course over another, since each situation must be evaluated
individually (U.S. Army Corps of Engineers, 1977).

COMBINED COST (X $4000)

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Another Corps study compared the costs of elevating structures (a
function of depth of expected flooding, height to which elevated, and size
of structure) to the market value of the structure. Empirical data were
derived from the Corps' Tug Fork Study. The resulting guidelines for the
cost of raising a structure are described in this table (Carson, 1975).

Ratio of Floodproofing Costs to
Value of Residential Structure

Floodproofing Height
Condition 2 feet 4 feet 6 feet

Sound 0.17 0.23 0.31

Deteriorating .0.65 0.75 0.90

Dilapidated 4.50 4.90 5.30

A homeowner's guide for floodproofing residential structures in
DeKalb, Georgia, provides rough estimates of the cost of making certain
modifications to a house and also of the savings to the owner in flood
damages.avoided. These figures are summarized in the following tables.

Wrapping house with poly-
ethylene; sealing exterior
walls. COST: $1,300 to $10,000

SAVINGS

Depth of Flood on First Floor
House Value 1/2' to 2' 3' to 5'

$30,000 $1,100 to 5,000 n/a
$50,000 .$1,800 to 8,200 n/a

Moving utilities, elevating structure; landscaping.
COST: to raise 3 ft: $7,800 to 14,300
to raise 5 ft: $10,000 to 16,500

SAVINGS

Depth of Flood on First Floor
Height of (before raising)
House Value Raising 1/2' to 2' 31 to 5'

$30,000 31 $1,100 to 5,000 $ 2,900 to 13,000
-30,000 51 $1,100 to 5,000 $ 4,000 to 18,000
50,000 31 $1,800 to 8,200 $22,000 to 26,400
50,000 5' $1,800 to 8,200 $23,800 to 34,600

(U.S. Army Corps of Engineers, 1979)

Sample Cost Comparison
One Story Frame - Brick Veneer W/Block Foundation
318 Essex Road, Baltimore, MD

Acquisition and Demolition

Purchase Value of Land (from worksheet) (20,000 sq.ft.) $ 8,000
Purchase Value of House (from worksheet) 31,000
Acquisition Expense 3,000
Demolition and Site Reclaynation
(from Table 111-6) 1,100
Resettlement 8,500
Total Acquisition and Demolition $51,600

Relocation

Relocation Cost (from graph) 917,600
.Adjustment for Brick or Brick Veneer
$0.80 x 1,200 (sq..ft. area) 960
Land Value at Existing Site $ 8,000
Land Value at Relocation Site 12,000
Larger of the Land Values -12,000
Value of Site Improvements 2,000
Overhead Traffic Signals
No. 3 x $250/disconnect 750
Overhead electric lines
No. - x $1,500/disconnect
Tree iemoval
No. 1 x $400/removal 400
Septic Tank and Well System (if required)
Supplemental Housing
Total for Relocation $33,710

House Raisiw, - V-411

Cost of -Laising (from graph) $15,800
Adjustment for Brick or Brick Veneer
$0.80 x. 1,200 (sq. ft. area) 960
Supplemental Housing 400
Total Cost of House Raising $17,160

Combinition House Raising and Utility Relocation

Cost of @::)mbination (from graph) $20,200
Adjustment for Brick or Brick Veneer
$0.80 x 1,200 (sq. ft. area) 960
Supplemental Housing 400
Total For Combination S21,560

(U. S. Army Corps of Engineers,
1977)

A few other general observations about thecost-effectiveness of flood
proofing are worth noting.

Economic feasibility increases with structure value and
frequency of flood with most measures feasible for a $30,000
structure only if located within the 25 year floodplain and, in
many cases, within the ten year floodplain. (U.S. Army Corps of
Engineers, 1976)

Floodproofing costs vary from 1-100 percent of the cost of
existing structures. (White, 1975)

In a sample of residences in Boulder Creek Flood Plain in
Boulder, Colorado, only 33 percent of the residences exhibited
positive net benefits from floodproofing. . In a parallel study,
the Corps of Engineers could identify only 24 homes out of 700
for which floodproofing was economically justified. (Flack,
1976)

Retrofitting industrial facilities can result in dramatic savings. A
feasibility study of a manufacturing plant in New England projected the
cost of a flood wall, water-tight doors, pumping system and related flood-
proofing measures to be about $200,000. Flood insurance on the existing
building was about $380,000 annually, and would have been only $10,000
after the adoption of the loss reduction measures, for an annual savings of
about $370,000 (Degen, 1979).

In another case, several industries in Lock Haven, Pennsylvania, were
analyzed to determine the feasibility of making modifications to buildings
to make them flood resistant and of constructing a levee to divert the
flood waters. The projected costs are expressed in the table on the next
page as a proportion of the damage experienced by the plant during the
Agnes flooding in 1972 (Ulp, 1979).

Elevating and Floodproofing New Structures

Most of the principals applied to elevating and floodproofing already
existing structures can be applied to buildings being contemplated for
construction. Certain measures can be highly effective when incorporated
into the building design, and often cost less than when added later.

A case study of different methods of floodproofing a new, small
commercial building in Jersey Shore, Pennsylvania, demonstrated that so
constructing the building in compliance with NFIP guidelines is "not unduly
costly" and is "economically feasible." The three approaches examined
(elevation on fill, partial elevation and equipping the building with
watertight closures, and raising on columns) increased the cost of construc-
tion from 6 to 16 percent. Coupled with the accompanying reduction in
flood insurance premiums and the reduction of expected flood losses, all
three options resulting in a savings (Sheaffer and Roland, Inc., 1977).
The benefit/cost ratios are summarized in the table on the second following
page.

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Benefit/Cost Ratios of Alternative Flood Proofing
Solutions for a Small Commercial Buildinga

ALTERNATIVE FLOOD PROOFING DESIGNS
Partially
Raised
On Fill
Wet Raised With Raised
Flood On Watertight On
Proofingb Fillc Closuresd Column se

Cost of Flood
Proofing per
Square Foot .$2.09 $1.60 $3.97 $3.91
Benefit/Cost Ratio,sf
1. Reduction in
Annual Insurance
Premiums-" Cost
ofFlood Proofing 0 5.96 2.31 2.48
2. Reduction in
Average Flood
Losses-L- Cost
of Flood Proofing 0.25 3.46 1.39 1.53

aBased on a multi-store commercial building of 22,500 sq.ft.,
proposed in Jersey Shore, PA
bAllows entry of flood waters to equalize hydrostatic pressure
on both sides of structural walls;does not meet minimum National
Flood Insurance Program requlations and can not receive a reduction
in flood insurance rates.
CRaised on fill 7 ft. to one foot above the 100-year flood
dRaised on fill 4 ft., equipped with 3 ft. of watertight
enclosures
eRaised on columns 12 ft. (6 ft. above 100-yearflood) to
accomodate parking
fCompared to the basic building without flood proofing

Source: Sheaffer & Roland, Inc., Economic Feasibility of Flood
Proofing: An Analysis of a Small Commercial Building;
prepared for theOffice of Policy Development and Research,
'Departmont@-df'Housing and Urban Development (1977).

Elevating a new house to the wave crest level associated with the
100-year flood increases the construction costs from 3.6% to 7.5%, but
this was more than offset by the reduction in insurance premiums and in
damages anticipated. This was the conclusion of a study of several differ-
ent types of construction and elevation procedures for residences in
coastal areas (FEMA, 1980). A sample of the figures upon which the conclu-
sions were based can be found on the following page. Another analysis of
the costs of new, elevated construction also reveals such action to result
in savings (FIA, 1977). Those calculations are illustrated in the diagram
on the-second following page.

The costs and benefits of "wet" floodproofing new structures are not
so well defined. The Sheaffer and Roland study cited above (1977) found
wet floodproofing to be uneconomical in the construction of a new commercial
building. In a review of the wet floodproofing literature, however,
Sheaffer and Roland (1979) note other contentions that incorporating wet
floodproofing into new construction adds "little or nothing to the initial
construction cost (Johnson, 1978, p.6; Jones, 1977, p.' 5). That review
also notes only one attempt to quantify the impacts of wet floodproofing on
damages: Jones (1977a) estimated that a combination of approaches could
reduce single-event damages up to 80% for shallow flooding and up to 55%
for deeper water (see Sheaffer and Roland, 1979, pp. 35-39).

Acquisition and Relocation

After a severe disaster or repeated flooding, property can be purchased
or otherwise acquired by the local, state or federal government, usually to
be left in open space, used for flood storage or put to some other use
compatible with the flood hazard. The damaged structure is sometimes
demolished, and sometimes moved to a new, flood-free location. Even though
acquisition and/or relocation are relatively expensive, both techniques
have enjoyed rather widespread use, largely because they are attractive as
permanent solutions.

A cost-benefit analysis conducted as part of a case study of the poten-
tial acquisition of flood damaged property in Panama City Beach, Florida,
illustrates some of the problems inherent in determining the cost-effective-
ness of this non-structural measure (Abeles, Schwartz and Associates and
Ralph M. Field Associates, Inc., 1978). Because acquisition is a permanent
solution, future annual costs must be taken into account. In this case,
values are converted to present values using an annual discount rate of
6 5/ 8% over 50 years. In addition, the costs and benefits vary depending on
whether one takes the position of the property owner, the local community
or the federal government. In this analysis a benefit/cost ratio was
calculated for each level separately, demonstrating that the proposed
relocation is economically justified from the individual and local perspec-
tive, but not from the national or federal ones. See the table on the
third following page.

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These tables show that for this home it would TABLE
be less expensive to elevate to or above the Average Annual Damage
base flood level than to build below it and Floor Elevation Probable Average
suffer loss. Above Grade Annual Damage

0 Ft. $1550
42 625
+4 160
+6 so

TABLE

Economics of Elevation for a $25, 000, One-S tory,
No Basement House in Zone A8

Option
D

Flood Insur.
Premium
Option $103
Base Flood Elevation 0 feet C
-------------------- ----------------------------------------------------------- k--------------
Flood Insur. Cost of
Premium Columns
$308 $2,458
Option
Expected Average Annual -2 feet B
Flood Insur. Cost of
Premium Columns
$790 $2,246
Damages at this site-$1550 -4 feet A
Flood Insur. Cost of Fill
Premium $1,470
$1503
Original Ground -6 feet

ANNUAL COSTS A C D

Annual Flood Insurance Premium $1503 $790 $ 308 $ 103
Additional Annual Cost of Elevation (30 yrs at 9%) 156 240 261
Total $1503 S946 $ 548 $ 364

Average Annual Damages Expected 1550 1550 1550 1550
Net Annual Savings by Purchasing Insurance and $ 47 $ 604 $1002 $1186

(FIA, 1977)
opt 'on
D

Flood In Sur_
P,em 'um
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B

Sur.
Floodlon
Prem um
$7,90

230-067 0 - 776

BENEFITS AND COSTS OF ACQUIRING ALL 23 ELIGIBLE
'IN
RESIDENTIAL D COI-U.IERCIAL PPOPERTIES
PANAMA CITY BEAC11,, FLOTRIDA
ANALYSIS OPTION I

Benefit/ Cost Accounts ($1,0001,s)

Local
National Federal Individual ComraunitV
A' PV A PV A PV A Pv

Total Benefits 131 203.8 - 25 383 17 269 .89 1386
Fiood Damage 42 649 @25 383- 17 269 - -
Reduction
Recreation 89 1386 - 89 1336
Total Costs 14 7' 2445 125 1922 3 42 31 481
Acquisition 144 2403 144 2403 - - - -
11.1oving Expenses 3 42 - - 3 42
Cont Sharing - (31) @48jj - - 31 481
a /,_, Ratio 0.93 0.20 6.40 2.88
Wit- Cost 16 407 100 1539 (14) (227) (58) (905)

Annual; PV Present Value

Abeles. Schwartz Associates/,Ralph 14. Field Associates

In a-study of the technical aspects of nonstructural alternatives, the
Corps of Engineers (1975) concluded that economic feasibility for a reloca-
tion project might be demonstrated at the-10 to 15-year level of protection.
Economic feasibility problems arise because of the high costs of purchasing
damaged units -- expenses which become p roject costs. These fair market
values, "when annualized over the life of a flood damage reduction project
will usually be greater than the average annual reduction in flood damageg
(U.S. Army Corps of Engineers, 1979).. As the table on the following page
shows, the break-even point usually occurs near the 15-year elevation. It
is easier to justify relocating more expensive structures.

One well-known example of a successful relocation project took place at
Soldiers Grove, Wisconsin. That case has been used to illustrate how a
cost-comparison framework can be set up to analyze two different options --
relocating the town or constructing a levee for protection. The table
shows a summary of the analysis, which supported the conclusion that
relocation is cost-effective over the long term (David and Mayer, no date).

Baltimore County, Maryland, chose acquisition of properties on eight of
its most hazardous floodplains rather than continue to pay for repairs and
disaster assistance. The 6-year plan called for purchasing 246 homes and
constructing four retention ponds, at an annual cost of $4.5 million, about
the same amount the County had been spending annually on spot corrections
and repairs. By the time the new strategy is fully implemented, however,
the troublesome floodplains will have been cleared, virtually eliminating
future damages and relief costs (Seyffert, 1977).

A study recently prepared for the Council on Environmental Quality
revealed that 280,000 acres of barrier island land had been developed by
1980, and that development of these flood-prone areas is proceeding at the
rate of 6,000 acres per year. At an average purchase price of $5,000 per
acre, the report concludes, "estimates indicate that acquisition costs
could be one-fifth or less of the costs to the federal government of
continuing its current development programs on undeveloped barrier islands"
(Sheaffer and Roland, 1981).

Troblems With Evaluating Individual Techniques

As is evident from the preceding review, there have been numerous
attempts to assess in some fashion the effectiveness of nonstructural
floodplain management techniques in reducing flood losses. Not all of
these attempts have produced satisfactory results, and it is still difficult,
if not impossible, to say whether.and to what extent a particular technique
will minimize losses and prove cost-effective. The principal problems
confounding the evaluation of nonstructural techniques are delineated
below.

Variable Situations

The biggest and most pervasive problem is that the settings in which
flood loss reduction techniques are needed vary so widely. Each waterway
has its own hydrologic characteristics, each floodplain its own morphology,

Results of hypothetical I-acre evacuation project using ER 1105-2-353

Evacuation without relocation Evacuation with relocation to
to a new site(2) new sites(3)
$15,000 structures - $50,000 structures $15,000 structures $50,000 structures
Average Average Average Average
Level of Benefit- annual Benefit- annual- Benefit- annual Benefit- annual
protection(4) cost ratio net benefits cost ratio. net benefits cost ratio net benefits cost ratio net benefits

10-year 0.77 -$1,400 1.08 +$11100 0.95 -$700 1.3 +$7,100

20-year 0.40 -3,700 0.59 -5,100 0.80 -3,000 1.04 +900

50-year 0.15 -5,300 0.23 -9,500 0.69 -4,600 0.85 -3,500

100-year 0.05 -5,900 0.08 -11,400 0.65 -5,200 0.77 -5,400

(1) Benefits for reuse of the floodplain and the other unique categories are additives for specific projects.
(2) Structures demolished.
(3) structures resold after relocation.
(4) Ground elevation surrounding structures.

(U.S. Army Corps of Engineers 1979)

-J

Zml

each flood its own duration and intensity, and each locality its own social,
economic and political attributes, all of which f igure in the ultimate
effectiveness of a particular mitigative approach. In addition, everything
changes over time. Even if one technique is adjudged "effective," such a
conclusion may not be applicable in another situation.

Estima ting Counterfactual Components

In determining whether the use of a particular technique has been
worthwhile, it is often necessary to estimate what would have happened had
the measure not been adopted. For example, if a structure has been flood-
proofed, a chief way to measure whether or not the action was cost-effective
involves estimating the difference between the damages incurred during a
flood and the damages that-would have been sustained in the absence of
floodproofing. The same sort of challenge occurs in projecting future
development trends in and out of a flood hazard area.

Measurement of Savings

Tied to the difficulty of estimating monetary losses and/or savings in-
alternative scenarios is the even more elusive problem of quantifying
non-monetary goals. The preservation of natural resources, wildlife
habitat and open space is a worthwhile, not uncommon goal, but one for
which it is a genuine challenge to assign an economic value. Beyond this,
there are not even generally agreed upon, specific objectives for nonstruc-
tural measures, nor are there standards by which to judge their effective-
ness in reaching those goals.

Systematic Methods

A variety of approaches to evaluating nonstructural measures has been
adopted. Sometimes cost/benefit analyses are done before beginning a
project; sometimes costs are monitored while a project is progressing and
savings are projected; sometimes an independent investigation evaluates one
or several projects in retrospect. Different standards of measurement,
different costs, and different assumptions make results hard to compare and
harder to generalize.

Lab Research

Although a few agencies such as the Corps have performed admirably in
this regard, there has still been insufficient testing of techniques under
"laboratory" conditions. Certain types of retrofitting and wet floodproof-
ing approaches in particular need more thorough investigation.

Post-flood Assessments

One of the prime opportunities for gathering information on types and
extent of damage, flood heights, and performance of protection techniques
is in th e immediate aftermath of a flood. Yet there has been no systematic
-attempt' to gather such data. Once buildings are cleared or repaired,
victims recovered and emergency operations personnel returned to regular
duty the accuracy and volume of the information obtainable diminishes
rapidly.

Funding

Insufficient funds have been allocated by federal, state, local and
private agencies for evaluating the projects in which they are involved.

Options for Improved Effectiveness Evaluation

There are numerous possibilities for improving the present status of
effectiveness evaluations. A few are outlined here.

� Systematic post-flood surveys should be conducted to capture as
much information as possible about types and extent of- damage,
location of structure and depth of flooding, and the specific
protection technique used. These surveys . might be carried out
through a team approach, modeled on the interagency hazard
mitigation teams. They should adopt a standard method, means of
measurement, and reporting technique and use the same ones for
every flood disaster.

� Insurance claims data maintained by the Federal Insurance Adminis-
tration and the disaster assistance claims data maintained by the
Federal Emergency Management Agency should be refined to provide
information -more useful to determining kinds of losses and
degrees of damage. It would be helpful, for example, to be able
to compare claims for damaged structures with data on the age of
the building and its elevation with regard to the flood hazard.

� There should be more laboratory testing of individual techniques
for their performance under different flooding conditions.

� A guide,book of evaluation methods would help to standardize at
least some components of the various approaches, and prevent some
duplication of effort.

� There should be a set of standards for quantifying such non-
economic benefits as natural values, habitat preservation and
storage capacity.

� Funds for on-going evaluation could be allocated as a small part
of the budget of any nonstructural project.

Bibliography

Abe les, Schwartz and Associates and Ralph M. Field Associates, Inc.
1978 A Case Study of the Potential Application of Section 1362 of the
National Flood Insurance Act.' Draft report submitted to the
Department of Housing abd Urban Development.

Bond, L.
no date "Flood Warning Systems: Use of Satellite Telemetry." Text of a
panel presentation. Phoenix: Arizona Department of Water
Resources.

Bresenhan, T.P.
no date "Adjustments to the National Flood Insurance Program." Testimony
before the Subcommittee on Hbusing and Urban Development and
Independent Agencies of the Senate Committee on Appropriations.

Carson, W.D.
1975 Estimating Cost and Benefits for Nonstructural Flood Control
Measures. Davis, California: U.S. Army Corps of Engineers
Hydrologic Engineering Center

David, E. and J. Mayer
no date "A Comparison of Costs for Structural and Non-structural Means of
Flood Hazard Mitigation: The Case of Soldiers Grove, Wisconsin."
Draft Report. Madison: Wisconsin Department of Natural
Resources.

Degen, J.
1979 "Flood Proofing of an Existing Industrial Plant: A Case Study."
In Industrial Flood Preparedness, Proceedings f a Seminar for
Industry. Lewisburg, Pennsylvania: SEDA-Council of Governments.

Federal Emergency Management Agency
.1980 Elevating to the Wave Crest Level: A Benefit: Cost Analysis.
Washington, D.C.: FEMA.

Flack, J.E.
1976, "Assessment of Research Needs on Non-structural Alternatives in
Flood Damage Abatement." In W.R. Kerns, ed., Implementation of
Non-structural Alternatives in Flood Damage Abatement. Proceed-
ings of a Conference on Informational and Research Needs.
Blacksburg, Virginia: Virginia Polytechnic Institute.

Illinois Department of Transportation
1982 "Protect your home from Flood Da .mage." Local Assistance Series 3B.
Chicago: Division of Water Resources.

1983 "Elevating or Relocating a House to Reduce Flood Damage." Local
Assistance Series 3C. Chicago: Division of Water Resources.

1984 Surveying Buildings for Flood Hazard Mitigation." Local Assis-
tance Series 3A. Chicago: Division of Water Resources.

Johnson, W.K.
1978 Physical and Economic Feasibility of Nonstructural Floor Plain
Management Measures. Davis, California: U.S. Army Corps of
Engineers, Hydrologic Engineering Center.

Jones, D.E.
1977 "The Economics of Water-Resistant Construction." Paper presented
at the Engineering Foundation Conference on Flood Proofing and
Flood Plain Management. Asilomar, California.

1977a "Early Floodproofing Limitations and the Fairbanks Contribution."
Paper presented at the Engineering Foundation Conference on Flood
Proofing and Flood Plain Management. Asilomar, California.

Kusler, J.A.
1982 . Regulation of Flood Hazard Areas to Reduce Flood Losses, Volume 3.
Report to the U.S. Water Resources Council. Boulder: University
of Colorado Institute of Behavioral Science.

McCoy, R.E., Jr.
1976 "Flood Proofing at Logan, Ohio and the Flood Hazard Factor." In
Proceedings of a Seminar on Nonstructural Flood Plain Management
Measures. Davis, California: U.S. Army Corps of Engineers
Hydrologic Engineering Center.

Milliman, J.W.
1983 "An Agenda for Economic Resear@h on Flood Hazard Mitigation."
Chapter 6 in S.A. Changnon, Jr., et al... eds., A Plan for
Research on Floods and Their Mitigation in the United States.
Final Report to the National Science Foundation. Champaign,
Illinois: Illinois State Water Survey Division.

Owen,- H.J. and M. Wendell
1981 Effectiveness of Flood Warning and Preparedness Alternatives.
Research Report 81-RO8. Fort Belvoir, Virginia: U.S. Army Corps
of Engineers.

Seyffert, J.D.
1977 "How Baltimore County Keeps its Residents High and Dry." The
American City and County (September): 78-80

Sheaffer and Roland, Inc.
1977 Economic Feasibility of Flood Proofing: An Analysis of a Small
Commercial Building. Washington, D.C.: U.S. Department of
Housing and Urban Development.

1979 Determining the Feasibility of Wet Flood Proofing for Non-residen-
tial Structures. Report A. Prepared for the Federal Insurance
Administration. Chicago: Sheaffer and Roland, Inc.

1981 Barrier Island Development Near Four National Seashores. Prepared
for the Council on Environmental Quality. Chicago: Sheaffer and
Roland, Inc.

Task Force on Federal Flood Control Policy.
1966 House Document 465: A Unified National Program for Managing Flood
Losses. Washington, D.C.: U.S. Government Printing Office.

Ulp, R.B.
1979 "Industrial Flood Proofing Study at Lock Haven, Pennsylvania."
In Industrial Flood Preparedness, Proceedings 2f a Seminar for
Industry. Lewisburg, Pennsylvania: SEDA-Council of Governments.

U.S. Corps of Engineers
1975 Estimating Costs and Benefits for Nonstructural Flood Control
Measures. Davis, California: Hydrologic Engineering Center.

1976 Formulation Criteria for Nonstructural Flood Plain Mana&ement
Measures. Davis, California: U.S. Army Corps of Engineers,
Hydrologic Engineering Center.

1977 Cost Report on N2n-structural Flood Damage Reduction Measures for.
Residential Buildings with the Baltimore District. IWR Pamphlet
No. 4. Ft. Belvoik, Virginia.: U.S. Army Engineer Institute for
Water Resources.

1978 Physical and Economic Feasibility of Nonstructural Flood Plain
Management Measures. HEC Research Document.

19719 The Development of Nonstructural Alternatives. St. Paul,
Minnesota: St. Paul District, Corps of Engineers.

1979 "Flood-proofing Primer." Atlanta: U.S. Army Corps of Engineers,
South Atlantic Division.

U.S. Water Resources Council
.1979 A Unified National Program for Flood Plain Management.
Washington, D.C.: U.S. Government Printing Office.

White, G.F.
1975 Flood Hazard in the United States: A Research Assessment.
Boulder: University of Colorado Institute of Behavioral ience.

PART III: MONITORING THE EFFECTIVENESS OF

COMMUNITY FLOODPLAIN MANAGEMENT PROGRAMS AN ISSUE PAPER

Thkslissue"paber is intended to stimulate discussion at the Monitoring
and-Effectiveness Seminar April 30 and May 1, 1984. Because of this,
the issues presented herein are left unresolved and the ongoing e 'fforts
subject to discussion at the seminar have been described only briefly.

CONTENTS

Page

Questions for Discussion at Seminar . . . . . . . . . . . . ... . . . 37

The Need for Community Monitoring . . . . . . . . ... . . . . . . 38

The State of the Art . . . . . ... . . . . . . . . . . . . . . . . . . 40

Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
Issues . . . . . . . . . . ... . . . . . . . . . . . . . . . . . . 43
Purpose . . . . . . . . . . . . . . . . .. . . . . . . .. . . . . . . 43
Targets . . . . . . . . . ... . . . . . . . . . . . . . . . . . . . 43
Methods . . . . . . . . . . . . . . . . ... . . . . . . . . . . . . 44
Data Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
Follow-up . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

Unclear goals . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
Limited Funds and Human Resources . . . . . . . . . . . . . . . . . 47
No Systematic Approach to Gathering Data . . . . . . . . . . . . . 47
No Systematic Assessment and Testing of Monitoring Methods . . . . 47
Little Comparison of Subjective Measures with Objective Ones . . . 48
Political Opposition . . . . . . . . . . . . . . . . . . . . . . . 48

Current Monitoring Projects or Programs . . . . . . . . . . . . . . . 48

TVA Evaluation Project .* . . . . . . . . . . . . . . . . . . . . . 48
On-site Evaluation . . . . . . . . . . . . . . . . . . . . . . . . 48
Survey Research . . . . . . . . . . . . . . . . . . . . . . . . . . 49
Subrogation . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
CAPEs. . . . : * * I * I * * * I * * * * I * I * * I * * * I * * * so
State Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . 54

Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

Bibliography . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

Questions for Discussion at Seminar

Given limited budget and staf f resources, what technique or
combination of techniques can a federal or state agency use to
monitor the effectiveness of community floodplain management?

Are mail questionnaires of any value? Are telephone surveys
reliable or useful? Are on-site surveys essential?

Are there shortcuts in conducting community surveys (e.g.,
meeting with community influentials)?

Are there good lead questions in conducting a survey or
holding a meeting?

Can aerial photography be used effectively? If so, how? Are
there other shortcut techniques?

Is it useful and feasible to compare.subjective information
to
(e.g., we have a good program") with objective information
(e.g., survey of elevations of a number of structures in the
floodplain)?

What follow-up is needed to a particular approach or set of
conclusions (e.g., letters sent to mayors and councilmen
where violations are discovered, legal action, etc.)?

How should a stateor federal agency select communities to be
monitored (e.g., random sample, number of structures in
floodplain, number of building permits, number of insurance
policies, recent flooding)?

Could or should on-site, telephone, mail survey, or other
monitoring efforts address such broader issues and needs
beyond education and enforcement of regulations as community
mapping, technical assistance, and public education? If so,
why, how, and at what cost?

The Need For Community Monitoring

a new start is necessary to provide essential informa-
tion 0 an ef f ective program of f loodplain management. . . . it
is important to show how much the Nation as a whole is losing
because of floods. . . the most important use of flood damage
data in the future will be for planning the use of floodplain
lands, establishing land-u.se regulations, and developing flood
insurance programs. . . .

One obvious solution would be to have data on all floods as
they occur collected by a designated agency. . . A second
possibility would be to maintain a continuing record of damages
for reaches of streams and coastal areas constituting a stratified
sample of the Nation's rivers,. hydrologic environment and land
use. . . It would be possible to . . . make damage studies only
as needed for project evaluation and preparation of flood hazard
reports . . . A more satisfactory solution would be to make . . .
periodic appraisal[s] [that) would yield results by which the
magnitude of the Nation's flood problem and the effectiveness of
its flood damage prevention programs could be adequately assessed.
(Task Force on Federal Flood Control Policy, 1966, pp. 19-21)

Local adoption of land use and construction controls is but
the start of the regulatory process in floodplain management. To
assure that these regulatory measures and objectives are readily
understood and accepted by government officials and the public
and thereby effectively carried out, there should be a continual
assessment of local capabilities and need for assistance.
(U.S. Water Resources Council, 1979, p. VII-19)

it is a disservice to the public for legislators to
ignore the need for resources to do comparative evaluations of
programs. . . For [the National Flood Insurance Program (NFIP)]
there is no current and reliable data set with which to conduct a
systematic analysis of the effects of the program in reducing the
national flood hazard. (Hutton and Mileti, 1979, p. 111-8)

After 15 years, relatively little is known overall about how
well communities in the flood insurance program are enforcing
floodplain management regulations. GAO found that FEMA's monitor-
ing program was limited, the method of selecting communities to
visit was inadequate, and the results of community visits were
not evaluated. (GAO, 1982)

Over the past several decades, concern with continually rising
national losses due to floods has ripened into a maturing framework for
both mitigating and coping with such losses. That nationwide framework
calls for the participation of federal, state and local governments as well
as providing for the contribution of the private sector and the
participation of individual citizens. Congress and the federal agencies
have developed a federal floodplain management policy, incorporating both
structural and non-structural techniques, and applying a national minimum
100-year flood standard. The NFIP has expanded to about two million
policies, and is coordinated with disaster assistance programsi The entire
nation has been mapped for approximate flood hazard and over half of the
flood-prone communities have been mapped in detail. The states have
assumed a pivotal role, providing technical assistance on flood loss
reduction to communities, enacting floodplain land use regulations, coastal
zone management programs and resource conservation statutes. Over 17,000
communities are enrolled in the regular or emergency NFIP, and have passed
floodplain land use regulations as appropriate. Regional, state and local
efforts to increase public awareness, to make productive and economic use
of flood-prone lands, and to involve private enterprise in the overall
process have become more and more common.

In short, considerable.progress has been made toward the establishment
of a comprehensive, coordinated approach to managing the nation's flood-
plains. It is too soon to tell whether flood losses nationwide are thereby
being reduced or at least stabilized. In the meantime, whether or not the
various components of the system iire functioning as envisioned is a crucial
question. If there are problems or deficiencies these must be remedied, or
adjustments made. If All is going smoothly, the concepts upon which the
program is based are reinforced; resources can perhaps be reallocated to
where they are most effective. To obtain this knowledge, various aspects
of the system must be monitored and as much information collected as
possible.

The crux of sound floodplain management is the local- progam. Even
though some guidelines, standards, incentives and financial support are
generated at federal and state levels, local governments are in the best
position to implement floodplain management. They are closest to the flood
problem since it affects most seriously their residents, employment levels,
and tax base. They have authority to regulate, acquire, zone and tax
property, and are routinely involved in the day-to-day procedures of land
use management and other community operations. Most aspects of the current
national framework for flood loss reduction, if not actually designed to be
carried out at the local level, have an impact right in the community. It
makes sense, therefore, to examine what communities are and are not doing
to reduce flood losses, which approaches are successful and which are not,
and how states and federal agencies can best assist the process. States
and federal agencies agree that monitoring is necessary and should be
designed to determine (1) how well communities are meeting their NFIP
obligations; (2) how well FIA's program elements are working; and (3) how
to deliver programs to overcome any problems that are revealed.

This paper discusses monitoring community floodplain management
programs and assessing the effectiveness of those programs. The first
section traces the development of community monitoring, describing some

past efforts and their conclusions. It also psets forth the main issues
surrounding the monitoring process and relates how often conflicting goals
and viewpoints complicate the procedure. The second section is a statement
of the specific problems that confront any monitoring program. In the
third section, current monitoring efforts by federal agencies, researchers,
and states.-are described. Finally, some tentative options to improve
y"" ome"
'some of the problem's.are, prese
communit@ monitoring and to over nted.

The State of the Art

Background

Because systematic floodplain management is a fairly recent develop-
ment, attempts to assess its nature and/or effects at the community level
were made only rarely up until a few years ago4 One of the early projects
was c-4rried'out by a group of researchers at the University of Chicago, who
were attempting to determine why flood losses continued to increase after
the enactment of the Flood Control Act of 1936.

Relying on air photos, field surveys, secondary data from the Weather
Bureau, Corps of Engineers, and the Department of Agriculture and developing
case studies, they analyzed changes in floodplain occupance in the 20-year
period from 1936 to 1957 in 17 urban areas. The study concluded that
decisions by public and private property owners had resulted in a substan-
tial invasion of flood-prone lands and a clear expansion of potential flood
hazard areas in those communities (White et al., 1958).

Case studies also have been conducted by various individuals and
agencies detailing the specific flood problems of a particular community.
Often this was done as a precursor to a proposal for a structural flood
control measure upstream or in the vicinity of the town.. The two agencies
usually responsible for such structural flood control measures, the U.S.
Army Corps of Engineers and the Tennessee Valley Authority (TVA), have the
longest histories of working with and providing technical assistance to
communities. Although both the TVA and the Corps have for the most part
maintained good working relationships with the communities in their jurisdic-
tions and have remained apprised of the flood problems faced there, neither
agency has had a real need to engage in actually monitoring the community
programs. This is due to the fact that structural flood control measures,
once implemented, require little active community involvement, and because
both agencies operate by providing technical expertise and advice to
communities when requested to do so, rather than dictating to the communi-
ties what actions they should be taking to manage their floodplains.

With the advent of the NFIP, and the accompanying requirements for increased
action at the local level, more attention has been given to communities by
researchers and agencies alike. A variety of approaches has been experi-
mented with in attempts to assess, monitor and evaluate both the activities
and impacts of community programs. Different tools are required to measure
different aspects of program activities, and this is well illustrated by
the diversity of approaches undertaken.

The management problems peculiar to small communities (under 10,000
population) were the focus,of another study (National Institute for Advanced
Studies, 1978). Mail 'surveys and on-site visits revealed that such communi-
ties are oftenlacking in awareness and understanding of NFIP information,
partly due to the relatively rapid turnover of elected officials. There
was a widespread desire for more "in-person" communication between federal
personnel and local administrators, in part to relieve.the common shortage
of local personnel available and equipped to oversee the program. It was
noted that even among small communities development pressures and trends
vary considerably and hence must be taken into account when assessing the
suitability and likely effectiveness of various management techniques.

Floodplain development pressures within communities and the relation-
ship of those pressures to federal programs were investigated for the
Environmental Protection Agency (EPA). Thirty-one localities, all recipi-
ents of grants through the EPA's "201" Wastewater Treatment Works Program,
were the subjects of case studies of their population trends, floodplain
characteristics, management techniques, and involvement with federal
projects and programs. In each instance an assessment was made of the
effect of federal programs in- directing, encouraging, or inhibiting economic
development on the floodplain (The Research Group, 1978).

As background for the preparation of a handbook on floodplain and
wetlands management, the Massachusetts Department of Community Affairs
(1977) conducted case studies of 18 eastern Massachusetts towns to determine
what they were doing, if anything, to regulate wetlands and floodplains;
how they were doing so, and why; how the local techniques paralleled state
and federal programs; and whether local experiences could inform the
administration of broader programs. Among other findings, the review
demonstrated that while some of the variation in local programs is due to
lack of guidance or resources, some of it can also be attributed to the
differing levels of control communities are willing and able to handle.

Two studies by Cheatham (1977, 1979) focused on the local land use
regulations required by the NFIP to determine whether they had succeeded in
limiting exposure of structures to flood hazard and, in the second instance,
had resulted in undesirable economic impacts. The information was obtained
by surveying realtors, contractors and building officials in the participat-
ing communities and by doing case studies of each community's building
permit records.

The process of community flood warning dissemination and response has
been investigated in order to isolate the determinants of a warning system
effective at-the local level (Leik et al., 1981). The researchers interview-
ed community organizations and households in thirty-one (31) study sites
and supplemented that information with lab experiments and the use of
communication hardware.

Case histories of ten successful community floodplain acquisi tion
programs were detailed in a project by Ralph M. Field Associates (1981).
The authors pinpointed the elements of successful programs to isolate
situations that favor acquisition of either developed or undeveloped
parcels on the floodplain.

A major study of local floodplain management practices focused on
changes in construction trends from the years before to the period after a
community enrolled in the NFIP (Burby et al., 1980). The investigation
operated on two levels. Local officials from 1,203 communities returned
questionnaires through which they assessed the exposure.to flood damage of
their community's existing and future development, the social and economic
problems of floodplain occupants, and the extent of human encroachment ' on
natural areas. The second level of analysis entailed the conduct of case
studies in three communities to determine what the community would be like
in the absence of a floodplain land use management program.

Recognizing that waterways and hence floodplains do not respect
politi "cal boundaries, one study investigated the effectiveness of inter-
governmental floodplain management practices. Using the case study
approach, Platt (1980) uncovered the issues, obstacles and responses of
jurisdictions that share flood problems in seven watersheds from Maine to
Oklahoma. Intergovernmental conflicts arose over whether or not to adopt
floodplain management measures; whether to rely on structural or nonstruc-
tural techniques; what level of protection to be reached; management of
natural storage areas that lay in more than one jurisdiction; and the
coordination of regulations and acquisition and relocation projects.

A number of options exist for achieving coordination among jurisdic-
tions. The study found that the tendency of federal programs to treat each
local unit separately provides no incentive for inter-community cooperation.
The most appropriate level is the substate regional scale -- county govern-
ments, special districts, regional planning agencies or watershed commis-
sions. Inter-local agreements, the exercise of extra-territorial powers,
and litigation also contributed to coordinated action in the case study
areas.

Communities with innovative flood plain management programs (those
that exceed the minimum action required by the NFIP) were the subjects of
75 case studies conducted with the intent of identifying common problems
faced by the communities, the keys to successful programs, and how the
lessons learned might be applied to other communities (Kusler, 1982).

Often detailed stud Iy of one locality's flood problems and floodplain
management approaches is made prior to the adoption of specific measures,
federal or state involvement in a major project there, or as a pilot for
other similarly situated communities. The Illinois Department of Transport-
ation (1979), for example, reviewed the flood problems facing Wilmington,
Illinois, and concluded by recommending no major structural control works
be built there and instead that the city undertake a regulatory approach to
keep flood problems from worsening and provide information and warning
programs to help flood-prone residents help themselves.

Harlan County, Kentucky, was selected as the pilot jurisdiction for a
detailed study of flood problems and management techniques in the Appala-
chian region. The goal of the project was to, identify a comprehensive
floodplain management approach that would help to limit or reduce flood
losses while still encouraging the economic development so vital to the
area. The case study findings and the final mitigation plan were released
as a manual for use by other communities (Booker, 1981).

Issues

This review, while not exhaustive and purposely omitting research
currently underway and on-goi -ng federal and state monitoring programs
(these are discussed below), illustrates the diversity of approaches,
methods, targets, and purposes for assessing community floodplain manage-
ment. No single monitoring technique is appropriate for every community
and every purpose. But the most effective, economical monitoring system
will be one that is designed after taking careful account of all the
various alternatives and addressing in advance those problems that may be
anticipated.

Purpose

The most fundamental issue by far is the purpose for which the communi-
ties are monitored. The range of community response to flood hazard and
the plethora of external factors that affect that response are so broad
that, unless a deliberate effort is made at the outset to keep specific
goals in mind, the information obtained will be so general and unfocused as
to be nearly worthless. In 'addition, the purpose will to a large extent
determine the data that are sought, the method used, and the communities
that are investigated. Unless the purpose is defined as clearly and as
narrowly as possible, the whole effort may well go awry.

The objdctives of the projects outlined above varied from trying to
discern differences in construction trends before and after community entry
into the NFIP, to uncovering any economic impacts of local regulation of
the floodplain, to describing the e 'xperiences of communities that had
acquired floodplain land or undertaken other innovative projects, to
analyzing how a community responds to a flash flood warning, to simply
documenting th 'e increase or decrease in the number of structures on a
floodplain over a period of years. States and federal agencies are interes-
ted in answering different and somewhat narrower questions: whether or not
a community has adopted an ordinance required by the NFIP, whether or not
it is enforcing the ordinance it has on the books, how thoroughly it is
complying with other state, federal or local standards, what kinds of
technical assistance it needs, or what action the agency might take to help
improve the local program.

Targets

The selection of the communities to be examined depends upon the
objective of the project. For research efforts that seek to produce
generalized findings, a random sample is usually drawn from communities
with appropriate characteristics. For more specific intentions, communi-
ties would be selected because they have the attributes that bear investiga-
tion: recent flooding, special high hazard areas, a large (or small) number
of flood insurance policies, or heavy development pressure on the floodplain.
In a continuous monitoring program such as the CAPE process, certain
communities might be scheduled for a visit every year or even every six
months*' "in order to maintain pressure on them to continue enforcing their
ordinances. It may be advisable to ensure private sector compliance as
well by continuously monitoring property owner behavior. This could be
accomplished by checking floor elevations of new, existing, and proposed
structures.

Methods

There are a number of different approaches that may be used to examine
local floodplain management. Questionnaires administered through the mail,
over the telephone, or in persons have enjoyed widespread use, but research-
ers have recognized strengths and weaknesses inherent in this approach.
Among the advantages, investigators note that survey research is capable of
marshalling data from a large sample at a fairly low cost. Many individu-
als in numerous communities can be reached, allowing cross-sectional
analysis and thereby improving the ability to identify and screen out the
intrusion of exogenous factors. A statistical analysis of a number of
communities makes it possible to identify causality between administrative
elements of the program and its impacts.

Survey research conducted with questionnaires has its limitations,
however. First, care must be taken to draw a representative sample.
Second, there are limitations to' the best sampling techniques and the
possibility of response error should not be minimized. Unfortunately,
valuable information may be unintentionally withheld because it is not
specifically requested on the questionnaire or is in a nonquantifiable
form. Even summarizing quantified data involves subjective evaluation.
Finally, mail or telephone surveys may reflect faulty local perceptions of
program effectiveness or even intentional misrepresentation and hence
should be supplemented by field observations.

On-site studies provide the advantage of being able to combine informa-
tion obtained through brief or in-depth interviews, personal observations,
and local records. If sufficient time is invested, on-site observations
may enable the identification of various exogenous or contextual factors at
work in a community that other techniques might fail to illuminate. Some
researchers are of the opinion that, in dealing with complex issues such as
floodplain management with its wide range of administrative variables and
often ill-defined community goals, such case studies are the only approach
that can prevent the blurring of factors that 'results from large surveys or
statistical analyses of secondary data sources. Case studies have been
widely used to evaluate flood management programs in the past by, for
example, Sheaffer and Roland (1981) and Ralph Field Associates (1981).

Chief among the drawbacks of the on-site study approach is its typical-
ly high cost in financial resources and in time. In addition 9 the degree
to which the case study approximates reality and provides thoughtful
analysis of causality is largely dependent upon the skills of the interview-
er and the technical knowledge of the field observers. The absence of a
large sample limits the ability to establish causal relationships. This
latter drawback could be overcome by conducting a series of case studies
guided by a uniform framework and designed to assure a stratified sample of
communities, but the cost of such an effort would be quite high.

Aerial photography and satellite imagery can supplement other research
techniques. Aerial photography is useful in determining changes over time
in the number of structures in the floodplain, and in measuring open space
and thereby reflecting the impacts of a local program. One study now in
progress (Galloway and Costello, 1983). has successfully used air photos to
monitor changes in land use in the Susquehanna River Valley in,Pennsylvania.

Remotely sensed imagery and computer manipulation of information for change
analysis are promising techiques, as well. They have been used on a small
scale and will likely play a larger role in coming years.

Data Sources

In each of the methods. outlined above, primary reliance is placed on-
data generated in the course of the investigation itself. Typically,
however, such approaches begin with assumptions drawn from data that have
already been collected, and proceed to combine secondary data from differ-
ent sources along with the newer information. Analyses are obviously only
as good as their data. Some secondary sources are fairly reliable, while
others are not. Problems arise when several sources of data are used to
enrich each other unless compatibility exists from one source to another.

Often the levels of aggregation differ, or are not appropriate to the
level of evaluation. For example, flood disaster data from the Red Cross
are aggregated at the Chapter level, FEMA's NFIP annual report data are
aggregated at the community level, and almost no data are easily accessible
at the individual level as a result of restrictions imposed by the Privacy
Act of 1971..

In addition to the problem of compatibility and level of aggregation
of data is the fact that the kinds of data that are collected change as
floodplain management becomes more sophisticated and complicated. For
example, a figure on the number of structures located in a given floodplain
might not be as useful a piece of information today as'it was five or ten
years ago because now some of those buildings are likely to be elevated or
floodproofed and thus are subject to less risk than their location might
indicate. Data collection efforts begun with the best of intentions can
become unusable within a matter of a few years as management practices,
@.techniques, technology and agency goals shift.

Follow-up

Almost all social science research investigations of local floodplain
management .are carried out on a one-time only basis. An exception is the
early White study of change in occupance on floodplains, which was replicat-
ed in part twenty years later to see what further changes had taken place
(Gruntfest, 1981). State or federal agency monitoring, which is geared
more towards ensuring compliance and improving local programs, needs
continuity or repetition to be effective. There are several avenues to
this achievement. One way to obtain practically constant monitoring of
some aspects of the local program is to set up a system whereby data are
reported and stored at a central location. Some states require that
building permits, for example, be filed with the appropriate state agency.
This can clue state personnel immediately about potential problems. A new
procedure being institued by FEKA will provide that insurance data from new
policies in the NFIP be automatically transferred to the regional offices
to-alert them about the variance specifications for a building under con-
struction, for example (see-table next page). This process will also help
to identify communities with ongoing development and better enable regional
offices to allocate resources toward community visits.

Insurance Data on New Policies Other Sources Help Identify
Identifies Communities With Potential Problem Communities:
On-going Development.and Minus Disaster Hazard Mitigation Teams
Rated Policies Annual Reports
Requests for Assistance
Consum r Complaints
State Agencies
Communities lath Communities Withl Insurance Claims Data
No Develo
pment Development Chronic Problems
Miscellaneous Monitoring

These Communities
Continue to be
Monitored Using CAPE Priorities Developed
Insurance Policy Based on Amount of
Data Development and Likelihood
for Administrative or
Enforcement Problems

CAPE Schedule Devel
By Regions

,CAPE Conducted By_ Possible CAPE Conducted By F
State, Corps, or Enforcement
Consultant Action

CAPE Data
Inputed Into
Program Clean fj [Technical Voluntary Enforcement
B@mluation Bill o Assistance Corrective Action
Provided ction Initiated
Data System Health FA
30-Day Show
KorrectiTe Actionjo- Cause Latte
Sent

30-Day Suspen-
lCorrective Action @-.sion Letter
Sent
Suspension7

Correct.;
.1 ;;@
Action

Reinstatement
77

The most common approach for community visits is for a state or FEMA
regional of f ice to plan to do a certain number of communities each year,
selecting these either at.random. or according to the level of activity or
degree of risk in the community. In these cases, some sort of follow-up is
needed. Problems discovered in a community might result in its receiving
further attention in the way of technical assistance from a state or
federal agency. The community might be targetted for a return visit within
six months or a year, or if growth and development pressures are strong, it
might be a candidate for a site evaluation every year. In some situations
more detailed examination of apparent problems would be required. Except
in a few areas such as New Jersey and FEMA's Region I, there simply are not
sufficient human and financial resources to conduct on-site visits of each
flood-prone community at regular, frequent intervals. This makes special-
ized follow-up procedures vital, and dictates that communities that are-
having problems be identified for particular attention.

Problems

Efforts to monitor community floodplain management programs have been
plagued by these problems. Current and future monitoring programs should
address as many of these as possible.

Unclear Goals

States, federal agencies and researchers all have had one and sometimes
several of the following purposes in mind: ensuring compliance with regula-
tions; encouraging adoption and enforcement of ordinances; assessing
mapping, education, and technical assistance needs; determining the cost-
effectiveness of various nonregulatory measures; determining the effective-
ness of regulations in reducing flood losses or in meeting other goals;
isolating those factors that contribute to the success or failure of
particular techniques; and understanding the processes at work in community
programs.

Limited Funds and Insufficient Human Resources

This is, of course, a perennial problem.

No Systematic Approach to Gatherin& Data

Information on flood insurance policies, claims data, disaster assist-
ance figures, community program annual reports, CAPE reports, state-super-
vised programs and various research projects all is collected through
different procedures, at different levels of aggregation, at different and
irregular intervals, and stored--if at-all--at different sites.

No Systematic Assessment and Testing of Monitoring Methods

A number of different approaches are used, making comparability
difficult, and it is not known which techniques produce the best results.

Little Comparison of Subjective Measures with Objective Ones

Certain aspects of local floodplain management, such as number of
structures at risk, can be measured objectively. For others, an informed
judgement may be the most accurate measure possible. It would be useful to
correlate these as monitoring proceeds. That is, how does a local, state
or federal official's assessment that a certain community has an "active"
or 11good" program square with data on building permits in the floodplain or
number of flood insurance policies in force?

Political Opposition

Sometimes communities resent federal and state interference in local
affairs.

Current Monitoring Projects or Programs

Sketches of efforts currently underway are presented below. During
the second day of the seminar, speakers described these and discussed how
they or their agencies coped with the issues and problems that confront
monitoring programs.

TVA Evaluation Project

, The Tennessee Valley Authority conducted a one-year pilot study (with
a second year anticipated) to evaluate the effectiveness of the local
floodplain management. programs in its jurisdiction as well as its own
services in assisting those communities. The TVA's approach, based on a
method developed by A panel of experts under the direction of the Natural
Hazards Research and Applications Information Center, calls for two staff
people (one planner and one engineer) to visit eight communities per year
for two to three days each. Local officials and community leaders are
interviewed, local records are reviewed and the floodplain is inspected.
These primary data are combined with a wide range of other information
obtained from TVA files, NFIP data bases, the state planning office and
other federal agencies.

The TVA's project assumes three main goals for floodplain management:
(1) protecting life and property; (2) enhancing economic development; and
(3) protecting natural resources. It adopts the administrative concept
presented in Chapter Four of A Unified National Program for Floodplain
Management. The investigation isolates the administrative tools used by
the.communities to try to achieve those goals and then assesses the extent
to which they are successful and possible reasons why that may be so.

.On-site Evaluation

Over the past few years individual researchers have developed methods
to evaluate the uses being made of floodplain lands, particularly in urban
areas. Case studies or "mini case studies" permit an assessment of the
extent to which the flood hazard area is integrated into the overall
community-development strategy.

Survey Research

A National Science Found at ion-spons ored study is being conducted at
the . University of North Carolina and North Carolina State University.
Using information and methods derived from a previous study, which involved
an extensive mail survey of communities, this effort will gather data on
the role of the states in floodplain management and measure the effective-
ness of their efforts.

Subrogation Surveys

In 1981 the Federal Emergency Management Agency sued two Louisiana
localities and several builders, developers and levee boards to recover
over $93 million paid out in federal flood insurance claims. The lawsuit
is based on the legal theory of subrogation which permits FEMA, as the
carrier of the insurance* policies, to "stand in the shoes" of the insureds
and bring legal action against those allegedly negligent parties that
caused the losses.

The General Counsel's Office of FEMA is now more systematically
collecting information about conditions in, other communties, in anticipa-
tion of bringing further subrogation actions if warranted.

Initial investigations of possible subrogation actions in flooded
communities are based on numerous sources of information: claims adjusters'
reports, damage survey and interagency team reports, citizen complaints,
LEXIS searches of lawsuits underway, CAPEs,. annual reports, the number and
size of map amendments locality has received, repeated disaster claims, and
monitoring of the 150-200 communities to which the -most insurance claims
are paid. The next step is to go, to the appropriate FEMA regional office
for specific data on the community's program--copies of maps and ordinance,
and the dates of the maps. The issue is what the community knows about its
flood problem and when they knew it. After consideration of an engineering
analysis, the nature of the evidence available and the likelihood of
success, a decision will be made whether or not to request the Department
of Justice to file a suit. So far 30-40 suits have been brought or joined.

Although a subrogation lawsuit may request relief in the form of a
judgement to be paid by the community to FEMA, the main goal of such suits
is the improveament of floodplain management, not the recovery of funds
paid. The lawsuit approach has several strengths: the cost and embarrass-
ment of a lawsuit can deter communities from violating NFIP requirements;
the discovery process provides an avenue for obtaining a good deal of
information about the community; a suit can be brought anywhere claims have
been paid--not just within the 100-year floodplain; and unlike with the
�1316 suspension alternative, in a lawsuit only the guilty parties suffer
the penalty. On the other hand, subrogation suits can only be brought
11after the fact," when damage has already been done; filing a lawsuit is
perceived as a heavy-handed alternative and not especially advantageous to-
the agency's reputation; and establishing proximate causation to win the
case--is always particularly difficult when flooding is involved.

The subrogation surveys provide a means by which the several hundred
most. frequently flooded communities are monitored. Subrogation could
become more widely used if CAPEs entailed questioning local officials about
lawsuits that had been filed by private parties; if windshield surveys were
done of the B and C zones; and if better information exchange occurred
among FIA, the states, thae regional offices, and FEMA General Counsel.

CAPES

In most areas- of the country the Community Assistance and Program
Evaluation visits (CAPEs) have been the chief means of monitoring local
programs. CAPEs are conducted either by regional FEMA staff or by state
personnel, usually with SAP funds. The FEMA regions conduct about 1,000
CAPEs each year. Each FEMA regional office takes a slightly different
approach to the conduct of CAPEs, depending on the needs and particular
situation in that region. A sample evaluation form from one region can be
found on the next page.

Region VII has developed a system to select and screen communities to
.determine which should be the targets of CAPE visits. Besides conserving
limited staff resources, this procedure also allows the,region-to identify
potential problem communities before serious violations occur. Each commu-
nity in the region was evaluated on the basis of five factors: development
pressure, large percentage of variances to permits, five years without- a
CAPE or over one year from conversion, no annual reports for three years,
and travel savings and efficiency. Communities with the highest aggregate
rating are contacted by telephone to determine if an actual CAPE visit is
indicated.

Over the past eight years Region IV has conducted 230 onsite, in-depth
CAPE visits which last about 231 days and involve at least two staff-members.
The region believes that thorough, face-to-face investigation and discussion
with local officials is the single best way to cope with the administration
problems posed by the NFIP. Their follow-up activities emphasize education,
regulatory measures and the potential liability of the local government
along with the risk of suspension from the NFIP.

Recently, one district of the Corps of Engineers conducted a series of
CAPEs as a pilot effort. The Soil Conservation Service does not participate
in CAPEs and has no interest in monitoring communities, but does see a real
potential for linking the results of CAPEs to SCS's regular activities.
The Corps could also provide data from its technical assistance visits to
FEMA to help alleviate its data gathering burden in the conduct of CAPEs.

Several states have assumed the major responsibility for carrying out
the CAPE process for communities in their own jurisdictions. For two
years, Wisconsin piggy-backed the CAPE procedure with their own community
audit process. Likewise, Illinois has conducted over 60 CAPEs on behalf of
FEMA's Region V office. California's interview report form (see the
second following page) shows issues commonly covered during a CAPE visit.

The Association of State Floodplain Managers and FEMA Region VIII have
conducted a survey of the states to assess their willingness and capability

FLOOD PLAIN MANAGEMENT REPORT

Chatam N.J. 340504 Morris N. J.
(Community Name) (Community ID#) (County) (State)

NFIP Status: X Emergency Regular Date of Entry
Purpose of Visit: Technical Assistance & Monitoring

A. Statistics

1) Population of entire community- [ ] 0-4,999 [X ] 5,000-9,999
[ ]10,000-24,999 [ ] 25,000-49,999 [ ]50,000 or more
2) Approximate population located in SFHA 297
3) Approximate number of structures in SFHA 72
4) Total number of permits issued in SFHA_0; for new construction 0
5) Number of variances issued in SFHA 0; for new construction 0
6) Number of insurance policies in force 49; new policies in force

B. Brief Summary of Findings and/or Discussions
Community officials appeared to be very environmentally
concerned about flooding and its empacts.

C. Resolution
Anticipated Actual
Resolution date Resolution date
1) [X] No Problem
2) [ ] Ordinance update completed
3) [ ] Enforcement procedures modified
4) [ ] Building violations corrected
5) [ ] FIRM and FHBM revised
6) [ ] Community put on "probation"
7) [ ] Community suspended
8) [ ] Other

D. Background

1) Has there been flooding within the last year? NO [X] Yes
2) Is there pressure to develop in the 100-year flood plain?
[X] NO Yes
3) Are there alternative sites available for development outside flood plain?
[ ] No [X] Yes
4) Are federally funded construction projects or actions taking place in the
flood plain? [X] No [ ]Yes

E. Innovations

1) Are structures being relocated out of the flood plain? [ ]No [X] Yes
2) Has there been any innovation(s) in the local FPM Program?
[X] No [ ]Yes

F. Enforcement

1) Is the community's ordinance compliant with NFIP Regulations?
[ ]Yes [X] No
2) Has the community submitted its annual report to the RO? 51
[X ] Yes [ ] No

CALIFORNIA
COMMUNITY INTERVIEW REPORT
FOR
NATIONAL FLOOD INSURANCE PROGRAM

A. BACKGROUND

1. Community Name
2. Status in Program:, F-1 Emergency Phase. Regular Phase
3. Date of Entry
4. Total number of permits issued in A Zone or V Zone areas during last 12 months for all new or substantially
improved structures
5. Number of variances issued
6. Reason(s) for varionce(s)
7. Hove permits been issued for filling, dredging, or grading in the A Zone areas? No Yes
8. Has there been any recent flooding? F7 No Y e s

B. ORDINANCE
1. Cite current city ordinance(s) pertaining to regulating the use and development of property in flood hazard
areas adopted
2. Are you experiencing problems interpreting any part of.your o-rdinance? N a Yes
C. PERMIT PROCESS
1. Who determines if development is within the flood hazard areas?

2. Who revidws..-per.mits?
3. Who makes periodic inspections7

4. Who maintains records of building permits?

5. Are the building permits that ore issued in A Zones maintained separately? N a Yes
6. Does the community have a system of periodic inspections to find out if structures have been altered or substan.
tially improved? F7 No F7 Yes
D. ELEVATION CRITERIA
1. Are structures being elevated to/or above the Base Flood Elevation?
a. Residential structures r7 Yes r7 No
b. Nonresidential structures Yes r7 No
c. Mobile homes F7 Yes r7 No
2. Who determines the base flood elevation?

3. What documents are used?
4. Does the minimum required lowest floor elevation appear on the permit, plans, or postconstruction
elevation certificate? F7 Yes No
5. Who inspects flood plain development to verify the lowest floor elevations?_

a. How?

6. Is the community recording the lowest floor elevation for all new or substantially improved structures?
-7 Yes '7 No

Where?

E. FLOODPROOFED STRUCTURES

1. Is the community recording the elevation of floodproofing when used on nonresidential structures?

Yes No

2. Is the community obtaining the required certification from a registered engineer or architect?
-7 Yes No

F. FLOOD PLAIN INFORMATION

1. Is there pressure to develop in the 100-year flood plain? No Yes
2. Are there alternative sites available for development outside the flood plain? No r-7 Yes

3. Are any federally funded construction projects or actions taking place in the flood plain? No Yes

4. Are any existing structures in the flood plain being relocated, floodproofed, or elevated? -11 No 7_1 Y e s

G FLOODWAY DATA

1. Has any development occurred in the floodway? No Yes
2. Is future development allowed in the floodway? 717 N a Yes

H. MOBILE HOMES

1. Are mobile homes allowed in the:

a. Flood Plains No Yes

b. Floodway No Yes
c. High velocity coastal areas --I No -7 Yes

2. Are anchoring or tie-downs required for new or substantially improved mobile home installations
in the flood plains? Yes No

1. OTHER

1. Is there a local review of all subdivision plans in flood plain areas? Yes No

2. Are environmental documents reviewed for planned subdivisions in the flood plain? Yes No

3. Have there been any local innovations implementing your flood plain management programs? No Yes-
If yes, describe

4. Have there been any structural channel improvements that affect the flood plains and streams, etc.? No Yes
5. Does the community have the current Flood Insurance Rate Maps, Flood Boundary and Floo.dway Maps,

and Flood Insurance Studies? No Yes
6. Is a review, revision, or update of the community's maps necessary? No Yes
7. Do you have any questions regarding in.surance rates or forms? No Yes
8. Do you have any questions about the NFIP procedures for appeals, map revisions, or
Letters of Map Amendments? No Yes

to perform CAPEs or other kinds 01 monitoring site visits. With 39 states
responding, the survey showed that the benefits of state performance or
assistance in CAPES are perceived to far outweigh the drawbacks. States
believe that they have a better understanding of local situations and pro-
blems than the federal government does and therefore can conduct more
effective monitoring and evaluation. Most states do not want to involve
themselves in enforcement follow-up to CAPEs, however, and no state conducts
CAPES without the aid of FEMA funds (Matulik et al., forthcoming).

State Monitoring

Wisconsin, North Dakota, Illinois, and Louisiana each have undertaken
their own monitoring programs. Wisconsin's effort was launched last year
with the design and test of a data collection and-analysis system to
evaluate the effectiveness of local programs.and to augment the pre-exist-
ing community auditing process. Wisconsin's program calls for each community
to be audited every four years. The new data base, which will continue to
be supplemented with new census, revenue and NFIP data, will enable the
state to measure changes in local management as years pass. North Dakota
has also begun to develop a format for. evaluating its local floodplain
management capabilities.

The State of Illinois' Division of Water Resources has conducted over
500 community assessment site visits over the last eight years, some of
them through contracts with reg ional planning commissions field advisors.
Using checklists, field advisors tour the floodplain and review office
procedures of the responsible local officials. Follow-up, activities
include.'letters, requirements of corrective measures and public meetings.

The State of Louisiana is completing the development of a comprehen-
sive computer data base called the SAFE system (systematic analysis for
floodplain evaluation). Containing over 5,000 pieces of information on
floodplain management techniques and funding opportunities, the system is
designed to assist communities in assessing the suitability of their
present efforts and in designing the optimal program for their specific
local problems (Louisiana Department of Urban and Community Affairs, 1983).

Options

It is evident that there is a number of different ways to monitor
community floodplain management programs. Any effort is composed of some
combination of the elements listed in the table on the following page. The
purpose is the most overriding of these, and determines which of the other
alternatives is selected. Once the purpose or purposes are clear, the
communities to be monitored can be selected and the frequency with which
that is to be done can be determined. The data that will be needed to
conduct the analysis also will be a function primarily of the purpose, as
will the decision about who is to conduct the monitoring. Af ter the
purpose$ targets, frequency and data needs have been identified, the
appropriate method or combination of methods can be chosen. The mode of
follow-up will be a result of the original purpose and of the findings
uncovered during the investigation.

Although in theory almost any combination of these elements is possi-
ble, in practice some work better than others, and any option will be
tempered by limitations in personnel, time, funding and political realities.
Besides the periodic assessments of various aspects of floodplain manage-
ment that will doubtless continue to be made by individual researchers, at
present three options for community monitoring seem most feasible.

1. FEMA or FEMA and other federal agencies could conduct a
community monitoring program.

If this were to be the case, which would be the target
communities? How frequently would an evaluation be done?
With what method? What data would be needed? What follow-
up should take place? (See table next page.)

2. States could conduct their own' community monitoring programs.

If this were the case, the same questions posed above would
need to, be answered. Also, how would the state's efforts
relate to federal programs like the NFIP?

3. Communities could be monitored through a cooperative state/-
federal program.

Again, the questions of approach must be answered. In
addition, how are the various tasks to be apportioned
between the states and the federal government? Could
regional agencies play a role? Could communities conduct
self-evaluation?

ALTERNATIVE ELEMENTS IN C OMM UNITY MONITORINC

PURPOSE

adoption
0 enforcement
0 technical assistance needs
0' understanding process

TARCET FREQUENCY CONDUCT DATA NEE DS

0every community a continuous * locals (self-evaluation) pr imary data (see method)
0random sample 0 every 6 months 0 states local records
0recent flooding 0 every year * FEMA regopms. 0 state files
high risk areas 0 random intervals * Corps 0 FEMA region files
development pressure 0 one time only 0 TVA 0 FEMA data files
0 other federal agencies (annual reports)
0 private firms 0 other agency data
researchers 0 disaster assistance data
0 insurance information
air photos

Method

0 mail survey
0 phone survey
a on-site visit
0 case study
0 field inspection
* local records
0 air photography
secondary data

FOLLOW UP

0 none technical assistance
a self-evaluation by locals more detailed survey
0 periodic repeat a NFIP. suspension
0 selected repeat 0 subrogation
0 subjective reporting modes *-legal action
0 monitoring by private group 0 aerial photography

Bibliography

Booker Associates, Inc.
1981 Harlan County, Kentucky: Flood Hazard Mitigation Plan. Prepared
for the Federal Emergency Management Agency, Washington, D.C.

Burby, R., S. French and E.J. Kaiser
1980 Managing Flood Hazard Areas: A Conceptual Framework for Evaluating
Program Effectiveness. Chapel Hill: University of North Carolina,
Center for Urban and Regional Studies.

Cheatham, L.R.
1977 An Analysis of the Effectiveness of Land Use Regulation Required
for Flood Insurance Eligibility. Mississippi State: Mississippi
State University, Water Resources Institute.

1979 An Assessment of Some Economic Effects of FIA Land Use Require-
ments on Urban Coastal Zone Development. Mississippi State:
,.Mississippi State University,.Water Resources Institute.

.Field' Ralph M. Associates, Inc.
19;1 State and Local Acquisition of Floodplains and Wetlands: A
Handbook on the Use of Acquisition in Floodplain Management.
Washington, D.C.: U.S. Water Resources Council.

Galloway, Col. G.E. and M.J. Costello
1983 "Monitoring Change in the Floodplain." Abstract #NR83-2.
Boulder: University of Colorado, Natural Hazards Research and
Applications Information Center.

Gruntfest, E.C.
1981 Changes in Flood Plain Land Use and Flood Hazard Adjustment in
Denver and Boulder, Colorado, 1958-1978. Unpublished Ph.D.
Dissertation. Boulder: University of Colorado Department of
Geography.

Hansen, L.L. and T.E. Hirsch
1983 Effectiveness Study of Wisconsin Floodplain Management Program.
Madison: Wisconsin Department of Natural Resources, Bureau of
Water Regulation and Zoning.

Hutton, J.R., and D.S. Mileti et al.
1979 Analysis of Adoption and Implementation of Community Land Use
Regulations for Floodplains. Final Report to the National Science
Foundation. San Francisco: Woodward-Clyde Consultants.

Illinois Department of Transportation
1979 "Report on Wilmington's Floodplain Program." Chicago: Division of
Water Resources.

Kusler, J.A.
1982 Innovation in Local Floodplain Management: A Summary of Community
Experience. Special Publication No. 4. Boulder: University of
Colorado Natural Hazards Research and Applications Information
Center.

Leik, R.K. et al.
1981 Community Response to Natural Hazard Warnings. Minneapolis:
University of Minnesota.

Louisiana Department of Urban and Community Affairs
1983 An Analytical PEocess for Selecting Floodplain Management Tech-
niques: SAFE. Baton Rouge: Floodplain Management Section, Office
of Planning and Technical Assistance.

Massachusetts Department of Community Affairs
1977 "Protection of Wetlands and Floodplains: Case Studies
18 Eastern Massachusetts,Towns." Boston: Department of Community
Affairs Office of Local Assistance.

Matulik, Mark, Tim Maywalt and Mary Lou Soscia
forthcoming "FEMA Region VIII Advanced Community Assistance Report."
Denver: Colorado Water Conservation Board.

National Institute for Advanced Studies
1978 Capability and Experiences of Small Communities With Respect to
the National Flood Insurance Program. Draft Report prepared for
the Federal Insurance Administration.

Platt, R.H. et al.
1980 Intergovernmental Management of Floodplains. Monograph #30.
Boulder: University of Colorado Institute of Behavioral Science.

The Research Group, Inc.
1978 Floodplain DEvelopment Pressures and Federal Programs. Prepared
for the U.S. Environmental Protection Agency, Office of Federal
Activities. Atlanta: The Research Group, Inc.

Sheaffer and Roland, Inc.
1981 Evaluation of the Economic, Social and Environmental Effects of
Floodplain Regulations. Washington, D.C.: U.S. Department of
Housing and Urban Development.

Task Force on Federal Flood Control Policy.
1966 House Document 465: A Unified National Program for Managing Flood
Losses. Washington, D.C.: U.S. Government Printing Office.

U.S. General Accounting Office
1982 National Flood Insurance: Marginal impact on Flood Plain Develop
ment -- Administrative Improvements Needed. GAO/CED 82-105.
Washington, D.C.: U.S. General Accounting Office.

U.S. Water Resources Council
1979 A Unified National Program for Flood Plain Management
Washington, D.C.:. U.S. Government Printing Office.

1983 Regulation of Flood Hazard Areas to Reduce Flood Losses, Volume 3.
Washington, D.C.: U.S. Water Resources Council.

White, G.F. et al.
1958 Changes in Urban Occupance of Flood Plains in the
United States. Research Paper #57. Chicago: University
of Chicago Department of Geography.

PART IV: SPEAKERS' PAPERS EFFECTIVENESS OF

INDIVIDUAL TECHNIQUES

COST-EFFECTIVENESS OF LOCAL FLOOD WARNING SYSTEMS

Curtis B. Barrett
National Weather Service

In determining the cost-effectiveness of local flood warning systems,
many factors must be evaluated. These factors include:

1. hydrologic characteristics of the river basin (e.g., time to
crest);

2. frequency of flooding;

3. population and structures located 'in the floodplain (poten-
tial flood damage, actual loss.of life and suffering);

4. lead time required for response actions;

5. type.of flood warning system selected;

6. present level of warning service;

7. need for data and hydrologic model analysis for purposes
other than flood warning: agricultural (multi-meteorological
sensors); water management; reservoir management; drought
analysis; and water quality.

These factors should be fully evaluated in deciding whether 'a local
flood warning system is economically justified and what type system is
required to meet the community needs. Unfortunately, very rarely is a
rigorous analysis conducted by a community to determine the benefits vs.
costs. In most instances, community officials are quite aware of a flood
problem and approach the National Weather Service (NWS) for advice and
assistance in implementing a local flood warning system. In almost all
cases, the community will purchase and maintain the flood warning system.

Very few studies are available in the literature which analyze the
cost-effectiveness of local flood warning systems. According to Bartfield
and Taylor (1980), a $50,000 ALERT (Automated Local Evaluation in Real
Time) system prevented $5 million in damages from a flood that occurred in
Ventura County, Calif ornia, in 1980. The Susquehanna River Basin Commis-
sion has published reports indicating that the Lycoming County manual local
flood warning system, coupled with floodproofing measures, has reduced
flood damages by 90 percent. The key to effective local flood warning
systems is providing sufficient lead time so that actions may be taken to
reduce flood damages and save lives. In addition, flood warnings must be
of sufficient accuracy to provide credibility and reliability for actions
to be taken. Finally, the lead time and accuracy must be accompanied by an
effective response system.

The relationship between potential lead time (time between the initial
occurrence of rainfall and the occurrence of flooding) and damage reduction
has been studied. This relationship has been expressed as a graph depict-
ing damage reduction as a function of lead time. Figure 1 shows a typical

graph for a suburban community located in a floodplain. Each community
will have a unique curve. This curve can be used to estimate the benefits
(flood damage reduction) by increasing the lead time. The effect of
increasing lead time can be quantitatively transferred to damage reduction.
However, the quantitative relationship between increasing lead time and
saving human life is unknown. One can only assume that by increasing lead
time loss of life will be reduced. This problem needs to be investigated.

Accuracy of flood warnings affects the credibility of the warning
(whether people will take action or not) and the extent of actions to be
taken (degree of evacuation). Accuracy varies according to the type of
local flood warning system selected, the quantity* and quality of the data
input to the warning system, the procedure or hydrologic model adopted and
the hydrologic characteristics of the river basin. In general, the greater
the accuracy, the more cost-effective the system will be.

A flood warning response system is an integral component of a local
flood warning system. A timely and accurate forecast is of little use if
it does not reach f lood- threatened residents. -Extensive planning and
preparation are vital to the effectiveness of flood warning systems.

Local flood warning systems can be categorized into manual and automat-
ed systems. Approximately 550 manual systems are in operation around the
country. These systems are cost-effective in the sense that little capital
costs are involved in their installation and operation. However, these
systems require constant attention or they break down. According to
Burnash and Bartfield (1980), who compared'the cost effectiveness of manual
systems to automated systems,. automated systems become more cost-effective
after six years of operation (see Figure 2). Approximately 100 automated
flood warning systems are in operation or are being developed. Automated
systems consist of flash flood alarm gages, ALERT systems, and IFLOWS
(Integrated Flood Observing and Warning System). Automated systems are not
only more cost effective in the long term, they provide reliable state-of-
the-art warning capabilities to communities with flood problems.

The cost-effectiveness of flood warning systems can be determined by
providing estimates of flood damage reduction and comparing these benefits
(reduced costs) to system costs (capital costs and maintenance). Flood
damage reduction can be determined by estimating forecast timeliness,
accuracy and response.

A computer program written by Dave Curtis while at the NWS Northeast
River Forecast Center computes economic benefits when considering the
cost-effectiveness of implementing a local flood warning system. A source
listing of this program is available from that office.

One. economical technique would be for the Tennessee Valley Authority,
Federal Emergency Management Agency, or other agencies to develop a ranking
system of communities vulnerable to flooding. Such a ranking system would
use such variables as potential flood damages, frequency of flooding,
interest df'the corhmurUty, available funding, and degree of flood prepared-
ness of the community. The State of Maryland is currently attempting to
develop such a ranking system in order to implement a cost-sharing proced-
ure for installing automated flood warning systems.

40,w
MAXIMUM PRACTICAL EVACUATION (MPE)'

30-

ZZ 23, ............................... . ....
z
0
20-

..........
z
w 10-

0 2 4 6 12 14 is 24 30 36 42 .48

FORECAST LEAD TIME (ERROR FREE) HOURS

DAMAGE REDUCTION= F LEAD TIME

FIGURE I

30
Automated system
20

10
Ic

1 2 3 4 5 6 7 8 9 10

YEARS

Comparison of accumulated real
costs of Automated System vs fully manual
System using cooperators

FIGURE 2
..........

SELF-HELP FLOOD DAMAGE REDUCTION IN
THE SUSQUEHANNA RIVER BASIN

Stewart K. Wright, Program Manager
Susquehanna River Basin Commission

Background

There are nearly 1,250 municipalities enrolled in the National Flood
Insurance Program in the Susquehanna River Basin. There are 55,000 insur-
ance policies with $1.9 billion coverage. Annual premiums exceed
$5 million.

Floods in the Susquehanna River Basin are frequent. There have been
eight major floods in 100 years and numerous smaller floods. There have
been three floods since December 1983.

Soon after its organization, the Susquehanna River Basin Commission
began a search for a solution to flooding problems. Several basin-wide
federal studies have been completed and investment of $460 million has been
made in structural projects, but annual average flood damages continue at
$40 million. The floods of 1972 and 1975 spurred a search for new flood
damage reduction approaches.

Two efforts were initiated. A large number of flood insurance studies
were completed. In addition, a study of the basin's flood warning system
was completed and recommendations for improvement were implemented.
Improvements in the National Weather Service River Forecasting System were
recommended. Over- 70 self-help flood forecast and warning systems were
organized. The self-help systems now provide flood warning for over one
million people in an 11,000 square mile area (about 40 percent of the
basin).
We have learned some important things from working with communities.
Many communities, especially smaller ones, have given up on the big federal
solution. - They have come to the conclusion that if they are going to
reduce flood damage they aregoing to have to take the lead themselves and
undertake a self-help damage reduction program. Demolition and clearing
flood-prone areas after flooding, floodplain management, strict
regulations, and locally constructed levees have all been part of the
approach. The development of locally-operated self-help flood forecast and
warning systems and emergency preparedness plans and actions have completed
this thrust. result is that in the Susquehanna River Basin a
comprehensive nonstructural flood damage reduction program is just
beginning to show results.

Self-help Flood Forecast and Warning Syste!@s

Self-help forecast and warning systems are simple and inexpensive to
organize and operate. Volunteers play a major role in keeping costs low.
Forecasting procedures supplied by the NWS are simple to operate. After a
few'storms accuracy can be increased. One county organized five self-help
watershed warning systems for less than $500 of county funds. The NWS
assisted with a field survey, inexpensive plastic rain and stream gages and
a forecast procedure.

Benefits have been substantial. There are accurate flood forecasts
for areas that did not have them before. These systems provide an accurate
and timely flood warning complement to NWS systems. We have concluded that
if it floods in less than 12 hours after heavy rainfall, you should use a
self-help system.rather than rely completely on the NWS systems.

A survey of two self-help systems following a flood identified over
$4 million in flood damages avoided. One industry developed an evacuation
plan that saved $3 million in damages and they were back in business
three days later.,

Flood Warning Response Evaluation Factors

A flood warning system does not operate by itself. These f actors
contribute to warning and preparedness.

I . What has been the previous experience of the community with
flood warning and action programs to reduce damages?

2. Compare the amount of warning time that is available with the
amount of time available for evacuation then design a warning
system thatbest fits the needs of the community.

3. The warning system must be able accurately to predict f lood
height and onset of flooding. The community must then
understand what the incremental f lood impact will be. The
flood stage forecast maps produced by the Susquehanna River
Basin Commission help accomplish this.

4. The warning function and the response function cannot be
isolated'from each other. The warning system must be able to
respond to unusual situations, and prepare rapid forecast
updates as a storm progresses. The key to this is redundancy
in trained people.

5. The community must have alternative means of communications
for both warning and managing emergency actions.

6. As warning reliability is improved so will the potential
benefits from a phased evacuation plan that considers the
special needs of elderly, sick., public facilities, and
industry.

7. Do not count on outside assistance. Use the resources that
are available.

8. Do a post-flood evaluation and make adjustments in the plan.

COST-EFFECTIVENESS OF ELEVATING AND
FLOODPROOFING NEW STRUCTURES

Larry Flanagan
U.S.Army Corps of Engineers

The cost-effectiveness of locating new, structures in the floodplain
and using elevation or other forms of floodproofing as a damage reduction
technique involves many variables.

One of the most basic factors involved is locational advantage. In
some situations, the question is.not a location outside the floodplain vs.
a.floodplain location: the floodplain location is essential. The question
-becomes how to best minimize the costs associated with floodplain occupan-
cy. Examples of this can be seen in the shipbuilding industry and other
riverine' and oceanic transportation businesses that must choose floodplain
locations, and in sewage treatment plants that often are located in flood
hazard areas because of functional necessity.

Another type -of locational advantage involves businesses that service
existing floodplain development. Ocean-front lodging facilities have
compelling economic reasons for floodplain locations and in many cases only
a few flood-free years will allow complete recovery of the initial capital
investment.

Floodplain developers with strong locational advantages such as those
described above are obviously prepared to pay a higher price for.,floodproof-
ing than the developer who simply has an opportunity to purchase floodplain
land-less expensively than flood-free land. The point is that locational
advantage, either real or perceived, is often the driving force in choosing
a floodplain location, and economic comparisons with non-floodplain sites
are not necessarily made.

Assuming the decision is made to locate a floodproofed structure in
the floodplain and local floodplain regulations do not limit the options,
the developer has several alternatives available. She/he can elevate the
structure with fill, piers, piling, or a wall foundation, use a levee or
floodwall, or use closures and sealants. She/he can also choose wet
floodproofing or a combination of two or more of those methods.

One of the most critical considerations of which technique to select
from both an economic and functional standpoint is the character of the
floodplain and the flood itself. Rate of rise, duration, depth, velocity,
and warning time are key factors. In a flash flood, the short warning time
may preclude the use of any measures requiring human intervention. High
velocities may preclude the use of fill because of erosion and could also
limit alternatives to raising on piers or piling. Long duration floods
also create problems for most floodproofing techniques except elevation.
Levees become waterlogged, underseepage becomes a bigger problem, and
pumping failures are more likely to occur as the duration increases.

The likelihood of the design level being exceeded is of particular
concern. If, for example, a 100-year design is used, the question remains
as to how much higher floodwaters can go. This is a very important ques-

tion, because if the 500-year flood is only 0.5 feet above the 100-year
flood, one can be very comfortable with the 100-year level of protection.
However, if the 500-year flood is 10 feet higheri catastrophic failure and
increased hazards must be considered.

Where it is practical, protection of new construction by raising has
by far the most general appeal. This method is essentially maintenance
free in many cases, very inexpensive, and exceedance of the design level
does not necessarily result in costly losses. For example, if a 4-f oot
levee or floodwall over tops by 0.5 feet, the protected structure could be
severely damaged. Conversely, the raised structure would receive only
minor damage. Raised construction is often, the only. method allowed by
local ordinances. Raising on piling or piers has the added advantage of
not restricting flood flows or reducing floodwater storage areas.

Most of the Corps' work in floodproofing has involved floodproofing
existing structures. In Corps project planning, consideration is given
only to structures presently sustaining damages, and according to Princi-
ples and Guidelines under which projects are formulated, it is assumed that
all new construction will be built at 'or above the 100-year flood level.
For that reason, the Corps has not become involved in cost studies for
floodproofing new structures, although the Flood Plain Management Services
organizations do provide general guidance on the various alternatives
available to the prospective floodplain developer.

Through its Flood Plain Management Services the Corps has attempted to
monitor.the cost and functional effectiveness of floodproofing systems. A
Corps publication, "Examples of Flood Proofed Structures," is presently in
final draft form. It presents a sampling of both successful and unsuccess-
ful floodproofing attempts from around the United States, and as much
factual information as possible will be presented for each example, includ-
ing cost and experienced effectiveness. In the survey f rom which the
examples are drawn, it is interesting to note that only about 50 percent of
the floodproofing attempts were considered successful.

In another rather unique project, the Corps, through the Waterways
Experiment Station (WES) and Tulsa District, is planning to demonstrate the
effectiveness of commercially available floodproofing systems by making a
house in Tulsa County, Oklahoma, available for testing. This project was
advertised in the Commerce Business Daily in February 1984, and two compan-
ies have expressed interest in testing their products. One company uses a
rubber sheet that is pulled up around the house during the flood, and the
other uses a paint-on sealant for walls and closures over doors and windows.
Both companies limit their system to three feet of protection to avoid
structural damage. The Corps will provide a levee and water for flooding
the structure, and will document the results in a WES Technical Report
which includes this and previous floodproofing research.

Louisiana State University Cooperative Extension Service has been
working closely with the Corps' Lower Mississippi Valley Division Office in
providing floodproofing assistance to home owners. They have recently
completed and documented a demonstration project showing floodproofing
techniques and are currently considering demonstrations of the effective-
ness of various types of low block and concrete floodwalls. Information

-sharing and joint funding of such projects by those involved could be
handled by a small interagency committee.

FLOODPROOFING BUILDINGS IN ILLINOIS

French Wetmore
Illinois Division of Water Resources

Being a very flat state, most of Illinois is subject to shallow, low
velocity flooding. This flooding can be frequent but often does not cause
substantial damage to a building. Flo6dplain residents are not subject to
high hazards and are not ready or willing to move their minimally damaged
building out of the floodplain. After a flood buildings are not substan-
tially damaged, making it difficult for floodplain regulations to mandate
relocation or other protection measures. The most appropriate response for
these properties is floodproofing.

In order to meet the needs of these residents, the Division of Water
Resources has undertaken a floodproofing advisory program designed to
assist as many people as possible. In 1979, we printed our first version
of 'Protect Your Home From Flood Damage. This manual advises residents on
everything from flood insurance to floodproofing, safety precautions,
cleanup, and. financial assistance. Our approach is to distribute the
manual to reach as wide an area as possible and then provide technical
assistance on request. The manual has been rewritten practically every
year as we learn more lessons from research, new floods, and discussions
with floodplain property owners.,

In 1982, we conducted our first floodproofing open houses. We distrib-
uted the manual to every person, presented a slide show of houses protected
with the techniques discussed in the manual, and invited local contractors
to set up displays and talked to those attending. We have also shown the
slide show around the state, adapting it to meet local flood conditions.

In 1982, we used supplementary , State Assistance Program funds to
perform two related projects. One was to conduct the basic research for a
more detailed manual that focused on elevating and relocating buildings.
The second was an extensive assessment. of public information programs and
what impact they had on floodplain residents' attitudes and behavior. One
interesting point is that this research found that residents that were
aware of flood protection measures perceived them to be economical. (The
one exception to this was flood insurance.)

As a result of this research and our direct contacts with floodplain
residents through the open houses and site visits, we have concluded that
it is not so important to stress the cost-effectiveness of flood protection
measures. The most important reason for this is that the funding for these
projects is coming from the property owners themselves. They are not bound
to conduct any detailed investigation and they will make their decision
based on their perceived need compared to the actual cost. Therefore, we
do not stress detailed cost benefit examinations but our manuals do provide
a general idea of the total cost of the projects and sources of financial
assistance.

According ly, for this paper,. I would like to focus on the various
techniques of flood protection and where they are most appropriate. In
1983, we used supplemental State Assistance Program funding to hire the

firm of Sheaffer & Roland to prepare a technique to survey buildings that
would tell us which flood protection measures are most appropriate for
them. This technique would be used as an initial planning tool in a local
flood mitigation effort.

We identified six categories of flood protection which are listed in
order of providing the most protection to the leasn demolition, reloca-
tion, elevation, levee or floodwall, dry floodproofing, and wet floodproof-
ing. Sheaffer & Roland identified the key factors that determine whether a
building can or should be protected by the measures. Following field tests
in three communities, we refined the work and published Local Assistance
Series 3A, Surveying Buildings For Flood Hazard Mitigation.

The key factors for this first round planning effort are characteris-
tics of the building and the flood hazard. Characteristics of the building
include:

0 General condition (unsound buildings 'are recommended for
demolition);

9 Whether the building is large or small (small 1-story or
2-story buildings can be moved or elevated easily);

0 Foundation type (buildings on a crawl space or basement can
be moved and elevated easily, while buildings on slab can be
dry floodproofed; and

0 Type of siding (masonr y siding can be dry floodproofed while
other sidings make for a lighter building which is easier to
elevate or move).

Given Illinois' riverine flood situation, we focused primarily on two
types of flood hazard: velocity and depth. Data for both of these are in
flood insurance studies. Because there are many areas in Illinois where
the floodway has a low velocity and shallow flooding occurs even during the
100-year flood, we did not automatically consider every floodway as a high
hazard area. We did decide that average floodway velocities of greater
than five feet per second should be consider a high hazard and buildings
should not be floodproofed or protected by levees in such areas.

We were concerned with flood depth in increments of three feet over
the first floor:

0 0.3 feet meant that masonry sided buildings on slab could be
dry floodproofed;

6 feet is the practical limit for a local floodwall or levee;

elevation was not con sidered feasible at depths greater than
nine feet.

The most difficult piece of information to collect is the depth of the
100-year flood over the first floor. For this we developed a technique
using a hand level and known ground elevations in the area to be surveyed.

This is the one part of the survey that is subject to the greatest error
and several warnings are included in the manual. One way to overcome this
shortcoming is to conduct the survey immediately after a flood and use the
high watermarks to calculate the depth of the 100-year flood. A separate
set of instructions are written in the manual for the postflood situation.

Once all the field data are collected on the survey forms the surveyor
traces each building through a flow chart. The flow chart identifies the
appropriate flood mitigation measures in order of preference. The surveyor
is advised to plot the results on a map of the neighborhood to provide the
basis for a general concept plan. Needless to say,the survey results need
to be reviewed with the property owners. In many cases interior inspections
by an engineer or house mover ate needed before final decisions are made.

'In our latest version of Protect Your Home From Flood Damage, we
discuss only five or six protection measures because we did not feel that
property owners are interested in. demolition. The manual covers the key
factors in lay terms and includes a comparative table summarizing how the
factors affect each measure (see next page). The cost ranges for elevation
and relocation are detailed in the manual, Elevating and Relocating a
House to Reduce Flood,Damage. They are based on recent projects in Illinois
as well as discussions with house movers.

Where do we go f rom here? I have three recommendations. First,
continue to promote property owner self protection with "popular" handbooks,
slide shows. and workshops. There should be established a repository or
library of public information materials and some review of what has been
successful.

Second, we need more research on the technical aspects of small levees
and floodwalls and wet and dry floodproofing. The Corps' Waterways Experi-
ment Station in Vicksburg and Hydrologic Engineering Center in Davis should
continue their excellent work. Other federal agencies should chip in,
particularly FEKA, which has over $100 billion at risk. There should also
be some focal point such as the Natural Hazards Center in Boulder to
prioritize research needs and prevent duplication of effort.

Finally, I am convinced that financial assistance is needed as the
final motivating factor to get property owners to protect themselves.
There are several federal agencies willing to spend millions of dollars on
flood insurance claims, disaster assistance, and structural flood control
projects, who should amend their rules and spend some of their money on
these flood protection measures. Detailed recommendations on how this
should be done were presented at the 1984 meeting of the Association of
State FloodplainManagers.

Comparative Table on Permanent Flood Protection Measures

Key Dry Wet
Considerations Relocation Elevation Levee/wall floodaroof floodoroof

Condition of small, wood small, wood large lot masonry unfinished
Building frame, on frame, on wells, basement or
crawlspace crawlspace on slabs garage
lor basement
Flood Hazard all types depth up to depth up to depth up to depth up to
9 feet, 6 feet, 3 feet, bottom of
lower shorter lower first floor
velocities duration velocities joists, lower
velocities
I
Floodplain no may be may be major no
Regulations restrictions required to prohibited rojects restrictions
elevate to in floodway %ubstantial
100 year improvements)
flood level may be
prohibited

Human no no usually: to yes: close yes: to move
Intervention close openings and contents and
openings and valves turn off
start pumps utilities

Technical house house soils expert. structural not
Expertise mover mover (engineer if engineer required
high velocity)

Cost Range $22,000 to $10,000 to minimal to minimal to minimal to
$67,000 $42,000 $15,000 $10,000 $5'CO0

Other eliminates insurance surrounding contents structural
Benefits worry premiums area not stay dry loads
reduced inundated reduced

Other new site dynamic erosion, overtopping, warning
Considerations pressures an overtopping static needed,,
foundation pressures basement
on walls purposefully
and floor, flooded

NOTE: 7h1s table only highlights certain factors to consider. For example,
any type of building can be elevated, it is just easier and cheaper to
elevate small, frame buildings an crawlspaces. Additional technical
expertise such as electricians, plumbers, and engineers is recommended
for all the categories.

.73

COST EFFECTIVENESS CONSIDERATIONS OF ACQUISITION/RELOCATION IN
FLOODPLAIN MANAGEMENT: THE SOLDIERS GROVE, WISCONSIN EXPERIENCE

Thomas Hirsch
Wisconsin Department of Natural Resources

Introduction@'

Located in southwestern Wisconsin's "Driftless Area," Soldiers Grove
started planning its acquisition of floodplain properties in 1975. By the
end of 1976, the community adopted a comprehensive program for revitaliza-
tion which included four floodplain elements:

1. Public acquisition and clearance of.all floodway properties;

2. Floodproofing of flood fringe residences;

3. Continuation of floodplain zoning to protect future develop-
ment from flood damage; and

4. Maintaining eligibility of property owners for flood insurance
during project implementation.

Although it. took a one percent flood event in 1978 to convince the
federal government of the wisdom of the community's plan and to muster the
required federal assistance, by 1982 the program was substantially complete
and had received widespread acclaim for its effectiveness in addressing one
percent flood protection, resolution of other serious threats to public
health and safety in housing, business and community facilities, community
redevelopment and economic revitalization, responsiveness of government,
wise energy management, and environmental enhancement.

Cost Effectiveness

As proposed and implemented, nonlocal costs were similar for both
structural and nonstructural solutions. This was later verified by the
David and Mayer article referenced in the issue paper. From the community's
viewpoint the overall benefits of the nonstructural approach outweighed the
costs even though the. local costs were far greater than they would have
been under a structural approach. The perceived benefits were in large
part non-quantifiable (and therefore were not included in traditional
federal benefit: cost analyses) but nonetheless real. The local perception
of the benefits depended in part on location: non-floodplain property
owners tended to discount benefit claims and to predict onerous tax burdens.
Nonlocal agency perceptions of benefits tended to be limited to their
agencies' "missions."

A number of costs associated with floodplain occupancy that units of
government experience under a "do nothing" scenario were not quantified at
Soldiers Grove because this scenario was not acceptable from other than
cost considerations. When other communities consider such floodplain
management alternatives as a small relocation program or permitting in-fill
development in a flood fringe, the "do nothing" costs will need to be laid

out for local and nonlocal decisionmakers. The more marginal the proposed
project is, the more critical these costs will be. They would include
incremental construction and maintenance costs of sewer, water, roads,
public and private utilities facilities, emergency services and flood
related health costs. These costs are ongoing, and represent current
public costs of floodplain occupancy.

Factors That Influence Benefits and Costs

Efficiency in planning nonstructural programs can be achieved by
planning before a disaster. One of the most critical and cost-effective
contributions is that of the public, particularly those to be affected by
the project. Waiting until after a flood disaster means trying to get
those persons to make imaginative and far-reaching decisions under condi-
tions of shock and loss -- something not likely to happen. Other lesser
cost factors include property appraisal values and other taking costs;
relocation assistance costs which in turn are dependent on the costs of
comparable replacement properties; the availability and affordability of
supplemental capital (particularly for commercial properties where reloca-
tion benefits are frequently inadequate); and the perceived ability to
achieve functional equivalency at the relocation site.

Recommended Approaches

For planning phases, timing is especially critical, as discussed
above -- predisaster planning with or without a phased implementation.
Because of the commercial nature of most of the displaced properties at
Soldiers Grove,.. minimum "down time". was important as well as the mutual
timing of any businesses which depended on each other. Participatory
planning by those who will be affected and those who will pay for the
project is essential so that common understandings are reached as early as
possible. Finally, the nature of the plans should stress appropriate
technologies to control costs and enhance local private debt capacity. For
implementation phases, sympathetic, on-site counseling is essential to
achieve successful relocations and to protect the integrity of public
assistance.

Transferability of the acquisition/relocation approach will depend on
three additional factors:

1. scale, in both manageability and impacts;

2. municipal legal powers and obligations; and

3. the community's ability to pay and its interest in doing so.

Do Other Studies Agree?

The 1984 Winter issue of the Journal of the American Planning Associa-
tion contains an economic analysis comparing the costs of the structural
and nonstructural alternatives at Soldiers Grove ("Comparing Costs of
Alternative Flood Hazard Mitigation Plans," David and Mayer, pp 22-35).
Total project costs were found to be roughly equivalent (levees $8.1
million vs. acquisition /relocation $7.0 million, 1980 dollars), ignoring
who paid for which parts.

How Was Cost-Effectiveness Determined?

The small scale and cohesiveness of the commu nity allowed a local
evaluation of alternatives on a comprehensive basis, one which included
quality of life considerations in addition to economic factors. This was
important because of the project's impact on the community. Local
officials made their decisions in a traditional manner, based on local
priorities (which at many meetings meant that dogs in the neighbors'
gardens were discussed as much as the relocation project), intuitively
including many nonquantifiables, and considering multiple purposes.

Nonlocal governmental decisions, by contrast, typically were single
purpose, short term,. non- risk taking, and limited to quantifiable
considerations. The same criteria persist today and are institutional
barriers any nonstructural project will have to overcome.,

Recommended Monitoring System

Given an acceptable data base, stage damage studies could begin to
define alternative cost scenarios. The costs of "doing nothing" discussed
previously also need to be enumerated. Any data base will need complete
structure inventories, which could be difficult on a large scale. Site
.visits are essential , to collect data and desirable as well so local
officials can understand the data system and use it in their
decisionmaking. Agencies must develop attitudes of assistance and not
project control. Such assistance is best provided close to a community, by
a regional or state agency. This implies that FEMA should encourage state
and local efforts to develop this capability.

ASSESSMENT OF ANNUAL FUNDING NEED FOR PURCHASE OF
FLOOD DAMAGED PROPERTY UNDER SECTION 1362

Report to the Senate Appropriations Committee from the
Federal Emergency Management Agency

Purpose

'The purpose of this report is to review program experience and provide
an estimate of national need and associated funding level to acquire
properties in flood prone areas that are subject to heavy and/or repetitive
flood damages. Section 1362 of the National Flood Insurance Act of 1968,
as amended, P.L..90-448, authorizes such acquisition of property.

This report has been prepared for and at the request of the Chairman,
Subcommittee of HUD Independent Agencies, Committee on Appropriations,
United States Senate. The request was generated as a result of concern by
residents and representatives of Mississippi River Basin States and else-
where that program funds have not been adequate to meetprogram needs.

Background

Section 1362 is an important part of the National Flood Insurance Act
of 1968, as amended, which established the National Flood Insurance Program
(NFIP). The NFIP is,a federal program enabling property owners to purchase
flood insurance. The program is designed to reduce the escalating costs of
property damage caused by.flood and the increasing federal disaster assis-
tance outlays for flood disasters. Theprogram is based on an agreement
between participating local communities and the federal government. This
agreement provides that the federal government will make flood insurance
available to property owners in communities which implement and enforce
programs -to reduce future flood losses through effective land use and
construction practices.

The federal government sets minimum standards, which a community must
..,meet in order to participate in the program. These standards are principal-
ly directed at new construction in the floodplain. Existing structures
built prior to a community's participation in the NFIP need only comply
following subsequent flooding which results in damages exceeding 50 percent
of the building's value or when improvements of this value are made,
regardless of the reason. Yet these existing structures are eligible for
flood insurance immediately upon a community's participation in the NFIP,
and premiums are subsidized by the federal government.

However, already developed areas can be subject to heavy and repeti-
tive flood losses. Consequently, actions are often warranted to reduce
exposure to flood risk. In these cases three basic approaches have been
employed:

1. Constructing structural measures; e.g., dams, levees, etc.,
designed to reduce the flood risk;

2. Floodproofing through retrofitting; e.g., elevation of an
existing structure designed to protect the structure from
flooding; and

3. Relocating structures out of the floodplains.

In passing �1362 of the National Flood Insurance Act, Congress recog-
nized the efficacy of acquiring and removing structures from a flood risk
area as part of the overall federal strategy for reducing flood losses. It
was determined that the public interest could be served by purchasing
insured properties that.have incurred significant repetitive flood damage,
been substantially damaged in a single casualty, or cannot be repaired
because a regulation precludes the repair or permits repair only at a
significant increase in costs.

The following objectives have been es tablished by FEMA for the �1362
program to meet the statutory criterion of serving the public interest:

1. To reduce future flood insurance and disaster assistance
costs by removing repetitively and/or substantially damaged
structures from flood risk areas;

2. To provide an opportunity for owners of repetitively and
substantially damaged structures to be permanently removed
from flood risk areas and to reduce risk to life from flood-
ing; and

3. To complement federal, state, and local efforts to restore
floodplain values, protect the environment, and provide
recreational and open space resources.

These objectives support the overall goals of the NFIP to reduce the
future costs of flood damages and to provide protection for property owners
against potential losses. As the next section will illustrate, not only
has the �1362 program resulted in cost savings to the taxpayers, but has
provided incentives to flood prone communities to help themselves in
addressing their flooding problems and strengthening their efforts in
effective local floodplain management.

The regulations implementing �1362 require that an application must:.

1. Show evidence that individual properties meet the statutory
eligibility criteria;

2. Include an agreement by the jurisdiction to remove the
damaged property without cost to FEMA; and

3. Show evidence of the state or local jurisdiction's legally
binding commitment to take title to and manage the property
in a manner consistent with sound land management and the
objectives of the �1362 program.

Other factors important in deciding whether a project should be funded
include: the potential reduction in future costs associated with flood
damages, the jurisdiction's commitment to floodplain management, the extent
to which the properties proposed to be acquired are contiguous, the quality
of the jurisdiction's plan for the acquired property, and the commitment of
other financial resources by the jurisdiction to complement �1362 funds.

Based upon experience, FEMA intends to improve the selection process
by developing a more systematic and objective method of evaluating the
potential cost savings for proposed projects and the other factors accord-
ing to their contribution to achieving the program's objectives.

Program Experience
Funds were appropriated initially in FY 1980 for th Ie acquisition of
flood damaged properties under �1362. The program is now in its f if th
year. Table I provides a summary of the first four years of program
activity. Table 2 provides a summary of the project applications received
for FY 1984 and the total amount requested. Determinations on all of these
applications have not yet been completed. To date, commitments have been
made for Baytown, Texas; Mansfield, Connecticut; and South Ogden, Utah.

During the Jirst four years of operation, the �1362 program has
accomplished much in relation to each of the program's objectives. In
general terms, substantial expenditures in repeated flood insurance claims
and recovery efforts have been' saved. Expensive flood control or flood
proofing projects have been avoided where they would not be cost effective.
State and local initiatives to reduce existing flood problems have been a
direct result of several projects. Funds from other federal agencies have
been used in combination with �1362 funds to expand the scope of a number
of projects. Other community benefits such as improved recreational
opportunities have resulted.

The extent of the actual cost savings resulting from any acquisition
project is 'difficult to estimate. @ Projections of future savings in flood
insuranee claims and premium subsidies and federal, state, and local
recovery efforts have not been attempted in any systematic way. Accurate
figures or estimates' of public expenditures prior to acquisition, upon
which to make current or future cost benefit judgments, are not readily
available. Nevertheless, based upon partial data and estimates, it can be
reasonably inferred that substantial savings in public (and private)
resources have been and will continue to be realized.

In the first �1362 acquisition project undertaken in 1980 in Clay
County, Minnesota, six properties were purchased for $556,000. Insurance
claims alone from three floods in 1975, 1978, and 1979, totaled $530,000.
Based upon the location of these structures (the lowest floor elevations
were an average of 20 feet below the 100-year flood elevation) and the
statistical probability of future flood damages, it has been estimated that
these properties would incur future flood damages of $1.0 million to
$2.5 million over the next 20 years.

In 1980, 117 properties in Lake Elsinore, California, sustained flood
insurance losses of about $2.0 million. Insurance claims do not accurately
reflect actual damages (estimated to be $4.0 million) since the city was
then in the emergency phase of the NFIP with the coverage limit of $35,000.
As a result of this flooding, the city adopted regulations which prohibit
the structural repair of any buildings with lowest floor elevations below
the 1980 peak lake level. Also, 36 of-the most severely damaged properties
were acquired for $2.3 million.

TABLE 1

Section 1362 Program Properties Purchased
FY 1980-FY 1983

Funds
Projects Properties Obligated

Fiscal Year 1980
Clay County, MN 6 556,0000
Gulf Shores, AL 5 1,068,400
Arnold, MO 34 831,334
San Bernardino, CA 22 1,639,364
Phoenix, AZ 7 336,822
N. Stratford, NH 1 58,000
Scituate, MA 9 446,650
Cowlitz County, WA 16 914,879
Project Administration -- 63,997
Subtotal 100 5,915,446

Fiscal Year 1981
Lake Elsinore, CA 36 2,23l,886
Belmont County, OH 2 38,182
Hull, MA 3 126,800
Peoria, IL 7 364,500
Lodi, NJ 6 395,900
Hamilton, WA 8 185,963
Lost Creek, WV 7 78,340
Project Administration -- 171,397
Subtotal 69 3,592,968

Fiscal Year 1982
Mobile, AL 20 1,031,000
Saraland, AL 2 74,115
Adams County, CO 1 25,500
Burton, MI 8 179,101
Project Administration -- 107,000
Subtotal 31 1,416,716

Fiscal Year 1983
Mobile,, AL 24 1,845,051
Scotts Valley, CA 1 102,090
Lake Elsinore, CA 1 76,829
Estes Park, C0 4 289,340
Chillecothe, IL 9 307,883
Lansing, IL 1 44,652
Peoria, IL 2 148,500
Tazewell, IL 2 102,289
Arnold, MO 38 536,605
Fenton, MO 3 24,000
Independence,MO 16 248,663
St. Louis County, MO 13 218,002
Whatcom County, WA 3 443,000
Project Administration -- 384,294
Subtotal 117 4,771,198

80 TOTAL 317 $15,696,328

TABLE 2

FY 1984 Applications for Section 1362 Funds

COMMUNITY OF PROPERTIES COST

Mobile, Alabama (111) 35 820S-655
Saraland, Alabama (11) 30 1,6562152
Satsuma, Alabama 14 1,278,750
+ Mansfield, Connecticut 3 170,000
Browning, Illinois 2 26,000
* Chillicothe Park District, Illinois (1) 2 61,398
Chillicothe Park District, Illinois (11) 1 29,943
DuPage Co., Illinois 7 442,700
0 Grafton, Illinois 3 59,000
Kampsville, Illinois 1 16,609
Project 13 3 38,500
Project 10 3 30,000
.Project 11 1 85sOOO
Project 12 1 12,000
Project 14 1 30,000
Liverpool, -Illinois 3 51,300
Rome, Illinois (II) (#l) 1 55,000
Project # 2 1 40,000
Project # 3 2 150,000
Project # 7 1 55,000
South Wilmington, Illinois 1 22,TO1
Village of Thebes, Illinois 10 116,700
Jackson, Mississippi 6 350,000
Vicksburg, Mississippi 9 325sOOO
119
Warren County, Mississippi 1,799,000
* Arnold,, Missouri (11) 4 21,992
Arnold, Missouri (111) 30 1s600,000
* Fenton, Missouri (1) 1 7,000
Jefferson County, Missouri 9 550,000
* St. Louis County, Missouri (1) 5 70,300
St. Louis County, Missouri (11) 100 2,000,000
Valley Park, Missouri 33 660,000
+ Baytown, Texas 250 1s500,000
+ South Ogden City, Utah 30,000
Hattiesburg, Mississippi 9 115,000
Canton, Mississppi 6 100,000
Fenton, Missouri (11) 8 84,000

@716 TOTAL $14,0459,700

Carryovers from FY 1983
+ Committed for FY 1984

Just three years later, the lake rose to nearly the 1980 level flood-
ing the same area. By. this time the city had also entered the regular
phase of the NFIP allowing for substantially higher flood insurance cover-
age amounts. Had the city and FEMA not taken the actions they did in 1980
to purchase those 36 properties, the direct losses to the NFIP alone are
estimated to have been over $2 million.

A similar situation where subsequent flooding has already occurred
following a �1362 acquisition is in Arnold, Missouri. In 1980, 34 proper-
ties were acquired for $831,334. Insurance claims and disaster funds
totalled about $1 million. At that time estimates of future damages over
the next 50 years ranged from $1.2 million to $3 million. In December 1982
a devastating flood struck the same area. An additional 57 properties in
Arnold, Fenton, and St. Louis County have been acquired for approximately
$800,000. Insurance claims for these newly acquired properties totalled
$1.4 million. The cost to the NFIP and to the disaster fund would have
been much higher had the earlier properties in Arnold not been acquired.

A final illustration of where substantial future cost savings can be
anticipated is the Brownwood Subdivision in Baytown, Texas. Formerly a
middle income subdivision of about 300 homes, subsidence since 1940 has
been 9k feet placing most structures zero to two feet above average high
tide and 14 to 16 feet below the base flood elevation. As a result,
frequent flooding has caused millions of dollars in damages, including an
estimated $3 million in NFIP claims, and dramatic deterioration of the
area. Homes with a replacement value of $80,000 or more now have a fair
market value of less than $30,000.

In August 1983. when hurricane Alicia struck, the whole, area was
inundated and many houses were totally submerged. Insurance claims are
expected to reach $6 million. Another $1.5 million will probably be spent
for temporary housing and individual assistance. An estimated $1.5 million
would have been required to repair such public facilities as sewers and
water lines. With the continuing subsidence and frequency of storms (since
1980 hurricanes have struck the Texas coast an average of once every
211 years), losses in the future would be in the millions even if the NFIP
requirements could be met.

Because nearly all the properties had flood insurance and claim
payments were equal to or greater than the f air market value, it was
possible at a fairly modest cost to break the cycle of a situation that
would continue to deteriorate. Although the final costs have not been
determined, it is expected that all eligible properties (290) will be
acquired for approximately $2 million.

The direct cost savings to the NFIP and disaster recovery efforts are
not the only economic benefit of the �1362 program. Another is that it
often offers a less costly alternative to other loss reduction measures.
Even where flood control or floodproofing approaches are possible, they are
often prohibitively expensive. In Phoenix, Arizona, for example, where
seven properties were acquired for $337,000, a study by the Bureau of
Reclamation and the Corps of Engineers estimated structural measures to
protect the area, which included these seven properties, would cost nearly
$100 million. Although it is apparent that a flood control project of this

size would involve more than seven properties, this example does illustrate
the order of magnitude that can enter into flood loss reduction decisions.

Similarly, -engineering solutions to the situation in Baytown, Texas,,
even if possible, would be extraordinarily expensive; nor would elevating
the six homes in Clay County, Minnesota, 20 feet be very practical.

A second major payoff of the program has been the leverage effect on
actions of other agencies or units of government. Local ordinances have
been passed that are more restrictive and comprehensive than those required
by the NFIP thus directing unwise development from the floodplain. New
programs have been undertaken to further alleviate the flooding problems.
State and/or federal funds have been used in combination with �1362 funds
to increase the number of properties acquired or to broaden the benefits to
the community.

The adoption of a comprehensive stormwater management program by the
City of Mobile demonstrates this leverage effect. Following heavy flooding
in 1981, a major acquisition effort was undertaken on the recommendations
of FEMA and the Federal Interagency Hazard Mitigation Team. FEMA initially
committed $1 million to purchase 22 properties. HUD agreed to contribute
$1.9 million of discretionary Community Development Block Grant money to
fund addition "al acquisitions and cover relocation expenses for the FEMA
acquisitions. In 1983, FEMA funded the acquisition of 23 additional
properties and is currently reviewing an application for 35 more. As part
of the overall plan to reduce flood losses in Mobile, the city agreed to
undertake the comprehensive stormwater management program.

In the Clay County, Minnesota, project discussed above, the acquisi-
tion of the six homes was the ke3f ingredient for the continuing effort to
acquire 11 vacant and adjoining lots and the creation of a regional park.
All of these lots have been acquired for delinquent taxes, or by donation,
or soon will be. The state has also appropriated funds to assist in this
effort.

Other examples of the leverage effect of the �1362 program are:

1. The ordinance adopted by Lake Elsinore prohibiting the
structural repair of any buildings having their lowest floor
located below the 1980 peak lake level;

2. The purchase , of six properties in Lodi, New Jersey, is a
small part of a redevelopment project involving federal,
state, and local funds to clear some of the floodplain and
convert it to recreation and open uses. This project will
also result in the construction of new moderate income
housing outside the floodplain connected with green space
fronting on the Saddle River in a park-like setting; and

3. In North Stratford, New Hampshire, $58,000 of �1362 funds
-were combined with HUD Community Development Block Grant
funds to acquire property,and relocate 60 families in an area
frequently flooded by ice jams on the Connecticut River.

These examples illustrate the range and magnitude of the benefits
resulting from the �1362 program. Most of the discussion has focused on
savings to the NFIP and disaster recovery efforts or the benefits to the
larger community through the creation of open space, recreational opportuni-
ties, and the like. Of course the ultimate benefit is to the. individual
home owner particularly those who want to sell and cannot. These are
owners who see their equity diminishing, cannot afford adequate insurance
coverage, or do not have the resources to do adequate flood proofing. Most
of the owners of properties' purchased through the program were in one or
more of these circumstances, particularly those who occupied their proper-
ties. This was true for middle income as well as lower income owners.
Many of these people purchased these properties with little or no knowledge
of the flood hazard and its consequences. For many of these people, public
acquisition programs such as �1362 are their only reasonable option.

Assessment of Annual Funding Need

In order to arrive at an estimate of the annual need for funding, a
variety of factors must be considered. The two most important are the
eligibility requirement(s) as defined by the statute, and the cost-benefit
of removing eligible properties from the flood risk area vis-a-vis such
other loss reduction approaches as flood proofing and elevation. Combining
these two factors with the property owner's willingness to sell and the
appropriate unit of government's commitment to accept title and appropriate-
ly maintain the propertyj the program need -is converted to what might be
more accurately called demand.

An estimate of annual funding, therefore, would reflect the number of
properties meeting each of these four conditions and the average cost per
property to be acquired. Average cost per property during the first four
years of,the program has been $47,447. This figure includes a few relative-
ly high-priced properties, particularly during the program's first year.
In 1983 the average cost per property was $39,000. Therefore, for purposes
of this estimate, an average cost of $40,000 will be assumed.

In the absence of data upon which to project future demand, an approach
will be used which builds upon a study completed in 1981 on the implementa-
tion of �1362 (Abeles et al., 1981). More current data and program experi-
ence will be incorporated. This approach will begin with an attempt to
define the universe of properties meeting statutory eligibility and then
reducing this number to reflect each of the remaining conditions; i.e.,
cost effectiveness, owner willingness to sell, and state/local government's
acceptance of title.

Using claims information from 1970 to 1979, the aforementioned study
concluded that, on an annual basis, approximately 0.1 percent of all flood
insurance policies for structures built prior to community adoption of
minimum federal standards for floodplain construction will meet the statu-
tory eligibility requirements for �1362. As of 1984, according to a study
prepared by the Federal Insurance Administration of FEMA (1983), there will
be approximately 1.8 million policies in force covering structures built
prior to community adoption of minimum Federal standards for floodplain
construction. Based on the information provided in these studies the
potential number of candidates for �1362 acquisition is approximately 1,800
structures annually.

As a check on this estimate of statutorily eligible properties, a
review of claims information on single family dwellings for the period
January 1, 1978 to September 30, 1982 was made. Using $36,000 as the
average value of the building (the value used in the 1981 study), there
were 7,324 claims over $18,000 during this period. This is an average
annual rate of nearly 1,550 claims. Theoretically this number of proper-
ties would have met the 50 percent damage criterion.

Data are not available to estimate how many properties would qualify
on the basis of the other two statutory criteria. The 1981 study indicated
that 98 percent of the properties would qualify on the basis of the 50
percent damage requirement. Program experience confirms that this is the
predominant qualifying criterion; however, the circumstances in Clay
County, Minnesota; Arnold, Missouri; and Mobile, Alabama, suggest that
qualification on the basis of repetitive damages ishigher than two percent.
Likewise, the experience in Lake Elsinore, California, and Baytown, Texas,
indicates that actions by local government may qualify some properties that
do not otherwise meet the specific damage threshold. In these cases,
repair and/or reconstruction of the substantially damaged buildings was
prohibited and building permits denied.

Though the exact number of structures which statutorily qualify on
average per year cannot be determined, claims data for the period 1970 to
1982 and program experience indicate that 1,500 to 1,800 claims is a
reasonable estimate. Of this number there is a substantial percentage that
do not meet the other conditions.

For example, a building which receives- 50 percent damage from a
100-year flood may be eligible for purchase but may not be cost-effective
to purchase since the statistical probability of another flood of the same
magnitude occurring during the remaining life of the building is low. This
would be particularly true when previous flooding was relatively infrequent
and minor. Program experience indicates that as many as 25 percent of the
total number of potential �1362 candidates would not be cost effective on
the basis of the low probability of a future event causing significant
damage.

In addition, many of these structures damaged greater than 50 percent
may be able to be retrofitted (either elevated or flood proofed) at a cost
less than that required for acquisition. FEMA is undertaking a study to
determine the feasibility and costs associated with retrofitting existing
residential structures for protection against flooding. Structures that
can be economically retrofitted may not be attractive candidates for �1362.
As many as 25 percent of the eligible candidates are likely to fall into
this category. Applying these reductions of 50 percent to the 1,500 claims
(the low end of eligible range) properties which meet statutory eligibility
requirements in an average year yields 750 properties that it would be cost
effective to purchase and remove from the nation's floodplains.

Without a systematic prospective process for identifying potential
ptdjec@ts it is very difficult to establish the expected frequency of owner
and/or state/local government unwillingness to participate in a �1362
acquisition. Historical experience indicates that using a 50 percent
factor for these two conditions would be a conservative estimate. Applying

this 50 percent factor to the 750 properties which are statutorily eligible
and cost effective to purchase, the final estimate for the number of
properties to.be acquired in an average year is 375.

Comparing this figure with recent experience of the program, indicates
that 375 properties is a realistic estimate. Total properties acquired, in
process of being acquired, or for which preapplications or applications
have been received from the beginning of FY 1983 to February 1, 1984, total
837 properties. Though not all of these properties have been evaluated, it
has been determined that the majority are good acquisition candidates.

The screening that normally occurs prior to the submission of a formal
preapplication would suggest that 750 to 800 of these properties would meet
the four conditions discussed earlier. From prior experience and knowledge
of preliminary work. on potential acquisitions, it can be expected that 50
to 100 additional qualified properties could be entered into the process in
time for acquisition in FY 84, were funds available. Thus for FY 1983 to
to FY 1984, 800 to 900 properties is a fairly accurate estimate of good
acquisition candidates.

In summary, based on historical claims information and relatively
short history in implementing �1362, FEMA estimates conservatively that an
average of 375 properties which meet eligibility criteria, are cost effec-
tive to remove, and for which community and property owner participation
could be expected, would be appropriate candidates for purchase. At an
average cost of about $40,000 per property, including administrative costs,
this would generate the need for approximately $15 million per 'year in
funding,to meet program needs.

Length and Flexibility-of Funding

The total number of floodplain properties which would qualify for
�1362 acquisition and would be cost effective to purchase cannot be deter-
mined based upon currently available data. However, it can be reasonably
anticipated that funding will need to be maintained at the level identified
in this report for the foreseeable future given the fact that the total
number of existing structures which do not conform to adequate flood-
plain construction standards is not- expected to diminish significantly
until after the turn of the century (Abeles et al., 1981).

A factor almost as important as the amount of funding available is the
way in which it is available. At present, funding is provided on a two
year basis. This eases some of the administrative problems associated with
responding to random acts of nature and carrying out a program requiring
long lead times with the need to obligate funds by September 30 of each
year. It does not, however, address problems of long-term flooding cycles.
Two high flood years consecutively could generate needs which the available
funding would be unable to meet. Alternative funding methods are suggested
below to make the program more responsive when this situation occurs.

1. Supplemental Appropriations The precedent for making addition-
al funds available to disaster related programs in unusually
high demand years, is nonetheless clear. A system of appropri-
ations, could be established whereby an additional level of

funding could be appropriated through the normal process but
only used when the basic appropriation was exceeded and some
Congressional notification had occurred.

2. No-Year Funding By not requiring funds appropriated in any
one year to be obligated by any particular date in the
future, FEMA could manage appropriations to allow the accumula-
tion of a reserve up to some maximum amount (for example, the
reserve could be limited to two times annual appropriations).
The President's Disaster Fund, established to allow governmen-
tal response to random acts of nature, is a good model for
the �1362 program. The ability to respond more flexibly to
needs as they arise will allow better long term planning of
property purchase as a part of overall NFIP objectives and
will allow better scrutiny to be used in the selection of
properties. This alone will generate better return on the
current level of investment. For the long-term it mity be
desirable to fund the program at a higher level, with even
more flexibility.

Conclusion

This report attempts to arrive at a reasonable estimate for annual
funding need for the �1362 Property Acquisition Program. Although reliable
data upon which to project program need with a high degree of confidence
are, for the most part,.not available, the approach taken is believed to be
supportable and logical. Those data that were used, though incomplete,
were consistent 'with the logic of the analysis. Where data were missing
with respect to a particular factor, conservative assumptions were made.
As a result, the estimate of the annual average number of properties to be
acquired (375) is probably on the conservative side.

References

Evaluation of Alternative Means of Implementing S2ction 1362 of the
National Flood Insurance Act,of'1968, research report prepared by the Joint
Venture of Abeles, Schwartz, Haeck711 and Silverblatt, Inc.; Ralph M. Field
Associates, Inc.; Federal Emergency Management Agency, March 1981.

"Impacts of Section 1362 Property Acquisition on the Insurance Component of
the National Flood Insurance Program," Office of Insurance Support Serv-
ices, Federal Insurance Administration, Federal Emergency Management
Agency, May 20, 1983.

PART IV (cont'd): SPEAKERS' PAPERS MONITORING

COMMUNITY PROGRAMS

MONITORING OPTIONS: QUESTIONNAIRES, TELEPHONE AND ONSITE SURVEYS

Raymond J. Burby
Center for Urban and Regional Studies
University of North Carolina at Chapel Hill

The choice of survey methods depends upon the types of data agencies
would like to obtain from communities and the weight attached to each of
five key questions that should be considered when evaluating alternative
data collection procedures. Each of the major data collection alternatives
-- onsite interviews and observations, telephone interviews,. and mail
surveys -- has advantages and disadvantages in relation to each question.
Which technique is best? The only straight forward answer is "It all
depends."

The first issue that agencies considering monitoring community flood-
plain management need to resolve is this: Is onsite observation of flood-
plain development necessary to -provide the information needed? In some
cases that may be so. For example, if agencies want to determine the
amount of error in meeting building elevation requirements, there is
probably no alternative but either to visit a sample of communities to
measure building elevations or to contract with a local firm to do that
work. In either case, there is little need to consider further the use of'
telephone and mail survey techniques, since once someone is onsite, face-to-
face interviews can easily be conducted at relatively little additional
expense.

In many cases the data agencies will want to obtain to monitor and
evaluate local floodplain management do not require onsite observation, but
can be provided by local officials or other persons involved in or affected
by the floodplain management process. That type of information can be
obtained through face-to-face interviews, telephone interviews, or mail
surveys. The choice 'of methods depends on answers to these five sets of
questions: How important is it that data be obtained from a representative
sample of communities and/or affected individuals and firms? How much
information is needed and how complex is it? What degree of accuracy is
needed? How soon is the information needed? and How much money can be
spent to obtain the information? Each of these questions is discussed
briefly as it affects the choice of survey method.

Obtaining a Re presentative Sample

In most cases, agencies will want to monitor and evaluate a representa-
tive sample of communities so that they will have some idea how well
floodplain management is being conducted and whether problems detected are
general in nature or unique to specific jurisdictions. Confidence in data
from a sample is much higher if random samples of communities or individuals
are selected for study. As a rule of thumb, samples of 100 or more units
of observation provide reasonable accuracy for generalizing to the entire
population. Random samples can be obtained f rom lists of the entire
population of interest using each of the survey methods. Obtaining a large
enough sample to have confidence in the results, however, sometimes affects
the choice of method when there is a budget constraint. Face-to-face
interviews usually cost 10 to 20 times more to conduct, and telephone

interviews three to four times more, than mail surveys. Other issues
involved in obtaining a representative sample are summarized in the table
below. Face-to-face and telephone interviews are about equivalent and both
have certain advantages over mail surveys. The major problem with mail
surveys is lower response rates (60 to 80 percent for a 12-page question-
naire versus 80 to 90 percent with telephone and face-to-face interviews)
and higher item non response. Also, it is more difficult to control who
actually provides information (fills out the questionnaire) with a mail
survey. Techniques are available to minimize those problems, however.

Amount and Complexity of Information Needed

A very large amount of information may be obtained from face-to-face
interviews (interviews lasting several- hours are possible with committed
respondents, such as agency heads). Telephone interviews may last up to an
hour with a very low proportion of respondents terminating an interview by
hanging up. In the case of mail surveys, response rates typically begin to
drop when questionnaires exceed 11 pages or 125 items. In addition to
requiring shorter data collection instruments, mail surveys require very
careful questionnaire construction and are not very useful in obtain open
ended responses or responses to items requiring prior screening to identify
appropriate respondents.

Degree of Accuracy Needed

Mail surveys have advantages over both face-to-face and telephone
interviews in obtaining accuratd information. Because respondents can
complete mail surveys as time -permits, if adequately motivated they will
look up needed data in agency records, make onsite observations, and take
other steps to insure that information provided is accurate that are not
possible with face-to-face and telephone interviews. Face-to-face inter-
views also suffer from a higher potential for what is termed "social
desirability bias" and interviewer distortion and subversion. Social
desirability bias refers to the tendency for respondents in face-to-face
situations to say what they think the interviewer wants to hear; in the
case of floodplain management, respondents would tend to respond in profes-
sionally appropriate ways, regardless of whether that was in fact the
situation existing in their community. With an anonymous mail survey,
candid responses are more likely to be obtained. Where face-to-face
interviewing is conducted by independent contractors there is the potential
for interviewer distortion and subversion; for example, interviewers may
not word questions appropriately or may fabricate interviews and data.
That is not an isolated occurrence in survey research; systematic checks
are necessary to insure that interviews were actually conducted.

Time Available for Survey

When the time available to gather data is a consideration, telephone
.surveys have definite advantages over face-to-face interviews and mail
surveys. With face-to-face interviews, time is required to travel to the
site and only about three to four interviews per day can comfortably be
completed per interviewer or agency staff person. If local interviewers
are used, time must be allotted for training and onsite supervision. Mail
surveys require approximately eight to ten weeks to be conducted properly

91-

(original mailing, postal card follow-up, plus two follow-up letters with
replacement questionnaires). In that time, 3,000 telephone interviews can
be completed, assuming a bank of 15 telephones and calling during working
hours. Thus,.once the number of interviews to be conducted exceeds several
thousand, the time required for mail and telephone surveys becomes compar-
able.

Personnel and Financial Requirements

Mail surveys do not require highly trained personnel to administer
them (though highly trained personnel are needed for sampling and question-
naire design and construction) and can be conducted fairly inexpensively
($3 to $5 per respondent for administration). Telephone. surveys require
trained interviewers or knowledgeable agency staff. However, since inter-
viewers can be closely supervised and monitored, less highly trained
persons than needed for face-to-face interviews can be used. Telephone
surveys generally run in the range of $10 to $20 per interview. Face-to-
face interviews require trained personnel, since interviewers are on their
own once they are in the field, and are expensive. Household surveys
involving face-to-face interviews often cost $100 to $150 per completed
interview. Surveys of local government personnel, which may involve travel
and per them expenses, may be even more expensive.

In summary, each of the three major data collection techniques reviewed
here has advantages and disadvantages. -The appropriate technique to use
depends upon data collection objectives and available personnel and finan-
cial resources. In many cases, a combination of techniques can be used
(e.g., direct observation of floodplain construction plus mail surveys of
local government personnel and community business and institutional lead-
ers) in order to improve the efficiency of data collection.

COMPARISON OF FACE-TO-FACE INTERVIEWS, TELEPHONE INTERVIEWS,
AND MAIL QUESTIONNAIRES

Performance Face-to-Face Telephone Mail
Characteristics Interviews Interviews Questionnaires

1. Obtaining a Representative
Sample
a. Known opportunity for all
members of population to be
included in sample. High High High
b. Control over selection of
respondents within sampling
units. High High Medium

c. Likelihood that selected
respondents will be located. Medium High High
d. Response rates.
1. Heterogeneous samples
(e.g., general public). High High Medium
2. Homogeneous, specialized
simples (e.g., agency
directors, ministers,
students). High High High

e. Likelihood that unknown bias
from refusals will be avoided. High High Low
2. Questionnaire Construction and
Question Design
a. Allowable length of question-
naires. High Medium Medium
b. Type of question.
1. Complexity. High Low Medium
2. Open-ended questions. High High Low
3. Screen questions. High High Medium
4. Controlling sequence in
which respondent sees
items. High High Low

5. Success with tedious
or boring questions. High Medium Low
c. Success in avoiding item
non-response. High High Medium
d. Insensitivity to question-
naire construction proce-
dures. High Medium Low
3. Obtaining Accurate Answers
a. Likelihood that social Low Medium High
desirability bias can be
avoided.

b. Likelihood that interviewer
distortion and subversion
can be avoided. Low Medium High
c. Likelihood that consulta-
tion will be obtained when
needed. Medium Low Medium
4. Administrative Requirements
a. Likelihood that personnel
requirements can be met. Low High High
b. Potential speed of imple-
mentation. Low High Low
c. Keeping costs low. Low
1. Overall potential for
low per interview costs. Low Medium High
2. Insensitivity of costs
to increasing geographi-
cal dispersion. Low Medium High 93

,.SOURCE: Don A. Dillman, Mail and Telephone Surveys: The Total Design Method,
New''-York:- -John'-Wiley, 1978.

WISCONSIN'S MONITORING OF COMMUNITY PROGRAMS

LuAnne Hansen and Thomas Hirsch
Wisconsin Department of Natural Resources

In 1968 the Wisconsin Legislature enacted floodplain zoning require-
ments for local governments. The Wisconsin Department of Natural Resources
(DNR), Bureau of Water Regulation and Zoning, is charged with administering
this state program by setting minimum state-wide standards and monitoring
local programs where zoning is actually implemented. , Zoning is just one
element of comprehensive floodplain management; many of these other elements
are under the aegis of other state agencies and bureaus with DNR. In 1983
the state decided to evaluate the effectiveness of its floodplain manage-
ment program by analyzing first local zoning programs and next, state
agency efforts and coordination in achieving the goals and objectives of
floodplain management.. This total evaluation is a necessary first step in
choosing new or additional policy directions.

The Department of Natural Resources has monitored local programs by
visiting with local officials on periodic audits. The present system of
community audits was initiated in 1980. A district staff person spends
one-half to two days in the community touring the floodplain, inspecting
files, and interviewing the community's floodplain administrators. These
audits are intended to provide technical assistance to the community as
wellas monitoring their progress. For two years the Wisconsin audits were
conducted jointly with FEMA's CAPE process. Each year 25 percent of
Wisconsin communities will be targeted for audits; thus the audit cycle
will be,completed every'four years.

The audit data formed the central focus for the DNR's effectiveness
study of local floodplain management efforts. The data were supplemented
with secondary data from census, revenue and NFIP sources. Additional
original data were collected from local community officials through a mail
survey. Telephone follow-ups were necessary to complete the partial
information supplied by many communities. Eventually 62 percent of the
surveys were acceptably completed. These data were entered into a computer
data base to facilitate statistical analysis. As new census, revenue, NFIP
and audit data become available they will be added to the data base, as
supplements rather than replacements to the existing data. This will.allow
us to measure changes over time within individual communities.

Q. Given limited budget and staff resources, what technique or combina-
tion of techniques can a federal or state agency use to monitor the
effectiveness of community floodplain regulations?

A. To conserve agency resources, state and federal agencies should piggy
back their efforts with other groups. FEMA's CAPE forms were easily
filled out as part of Wisconsin's audit process because we asked many
of the same questions. Not all communities can be audited. It is
desirable to set priorities based on critical needs. Wisconsin used
easily obtained secondary data sources to determine priorities for
visits.

Q. Based upon your experience, are mail.questionnaires of any value? Are
telephone surveys reliable or useful? Are onsite surveys essential?

A. Our experience showed that mail surveys often needed telephone follow-
up. In the future wehope to mail the forms out, then fill them in by
interviewing the local official over the phone after he/she has had
time to gather the necessary data from office files. Onsite visits
are essential for accurate monitoring. We found that floodplain tours
turn up problems that might be glossed over in the files or interviews.

Can aerial photographs be used effectively? If so, how?

A. Aerial photographs could be used to identify buildings within the
f loodplain limits and to roughly determine uses (open space, residen-
tial, industrial) of the floodplain. But elevations cannot be deter-
mined f rom aerial photos, so in Wisconsin where properly elevated
flood fringe development is allowed, the photos could not help us
identify how many structures are actually "at risk."

Q. Did you compare subjective information with objective information?

A. We tried comparing subjective information (mostly from the yes/no
questions on the CAPE form) with objective observations (variances
granted, disaster rates, new at-risk development). We were unable to
find any significant correlations between the subjective and objective
measurements. Our staff were asked to rate communily effectiveness on
a subjective scale. Again the staff ratings could not be correlated-
with objective measures of floodplain management effectiveness.
Wisconsin continues to research this subject.

Q. What follow-up is needed to a particular approach or set of conclusions?

A. Wisconsin's audit follow-up involves recording recommendations (new
maps, ordinance changes) then assigning deadlines and staff personnel
to implement the recommended steps. The follow-up procedure is on a
spread sheet in our main computer file so both central and district
staff can note task assignments and record their progress in achieving
those.

Q. How,should a state or federal agency select communities to be monitored?

A. Wisconsin will seek to monitor every ordinanced community at least
once every four years. For some communities this may be. only a 30
minute drive-through and drop-in visit. But we will also use a
priority system to select communities that will be visited more often
or communities to receive an extended technical assistance visit. The
audit priority system will be built around such measurements as:
population, extent, type, and changes in floodplain development;
recent floods, insurance claims, and future growth predictions.

Q. Could or should onsite telephone mail survey or other monitoring
efforts address such broader issues and needs beyond education and
enforcement of regulations such as community mapping, technical
assistance, and public education? If so, why, how, and at what cost?

A. Combining monitoring and technical assistance in one community visit
has both advantages and disadvantages. The combination approach saves
on staff,time and travel expenses. The staff person's approach for a
truly objective monitoring interview would be much different than if
that person were trying to inform and educate. Monitoring efforts
need to be standardized among various interviewers. This means the
questions in the interview need to be asked in order and as written.
The monitoring interviewer needs to remain a neutral observer and
recorder to keep from adulterating the respondents answers with
his/her own ideasi While the goal of each kind o 'f interview is to
stimulate discussion, the program monitor must remain more neutral
than the trainer. Similarly the local official being interviewed is
going to react differently if he/she-knows he/she is being monitored
than if the goal is education. The image and authority of the inter-
viewing agency (regulatory vs. assistance) will also influence the
local official's responses. FEMA and the states need to reconsider
this issue of mixing the two functions. While the two might be
effectively combined, we need to know how monitoring results will be
affected.

MONITORING FLOODPLAIN MANAGEMENT TECHNIQUES AND
COMMUNITY PROGRAMS

Mary Fran Myers
Illinois Division of Water Resources

Monitoring the ef f ectiveness of local f loodplain. management programs
is appropriate for federal and state agencies involved in floodplain
management for two reasons. First, these agencies should promote objectives
directed at the wise development of this nation's floodplains and the
reduction of susceptibility to flood damages. Since local floodplain
management programs. make or break the objectives, by monitoring the locals
the agencies evaluate themselves.

Second, if local governments are not doing their job, then some states
have the explicit authority (others have implied authority, and some none
at all)-to manage floodplains themselves. Where the state does not fill in
this gap, the federal government has responsibility -- at least in ensuring
that federal tax dollars do not return to lackadaisical communities. if
local governments@are not monitored, how do state and the federal govern-
ments know when they must assume this responsibility?

The big question is to determine how to monitor local governments
within the limits of the budgetary constraints set by various legislative
,bodies. This paper addresses these issues from the perspective of a small,
rural state.

The best technique to monitor communities is through' one-on-one
contact with those communities. While this process is costly and time
consuming, it is the only way to get a truly accurate picture of a communi-
ty's floodplain management program. Until that initial face-to-face
contact has been made, effective communication with local governments
cannot be achieved.

Once the contact has been made and assuming a good rapport is estab-
lished with the community, then monitoring with less expensive, less time
consuming methods can be used. For example, annual reports can be employed;
maintaining contacts with regional planning organizations can supply useful
information; and region-wide workshops or seminars can be beneficial to
target areas for closer monitoring attention.

Mail surveys do have some value. This is particularly true when the
person completing the survey has already had the opportunity to have
personal contact with the responsible agency, and to know the purpose of
floodplain management programs. Mail surveys can also be beneficial by
providing basic information (such as the data collected in NFIP annual
reports) and in identifying areas in need of help (such as those that
respond "yes" to the question on the annual report, "Are you in need of
technical assistance?").

There are two problems with mail surveys. First, not everyone fills
them out. A 50 percent return on a survey is considered a great response.
That may be true when gathering general information in an entire area, but
it is not true when you want to monitor Community X's compliance efforts,

and Community X happens to be one of the 50 percent that did not respond to
your survey.

The second problem, particularly with surveys long and complex, is
that people will not take the time to carefully fill them out. Two examples
come to mind. The one conducted by Ray Burby at UNC was fairly lengthy and
asked some thought-provoking questions. Of the f our copies of the survey
sent to people at the State Water Commission in North Dakota, two were not
completed. People were simply too busy to take the time needed to adequate-
ly answer the questions. The, other survey is the ASFPM Map Initiatives
Project survey. The time needed to carefully review the sample maps and
answer the survey is considerable. In Illinois, to combat this problem,
the questionnaire was shortened and distributed at a building officials'
conference. By doing this, at least some input was acquired from the
people who use the-maps to manage floodplains.

I believe there are short cuts in conducting community surveys. In
doing one-on-one meetings, it is possible to conduct several per day. By
spending a week on the road, it is possible to hold 10 to 15 meetings. I
believe that is very cost-effective.

It is important to meet with the right people. It is necessary to
meet both with the person with the authority 'to make decisions and policies,
and the person with the responsibility for implementing those decisions.
If possible, a community monitoring meeting should involve both groups to
be truly effective.

Perhaps the best time and cost saving device is to draw some conclu-
sions from a few community monitoring efforts and forget about monitoring
others. It is likely that 95 percent of small rural communities partic@ipat-
ing in the NFIP all have the same problem: they are not aware of their
floodplain management responsibilities. Rather than taking the time to
.review each and every community, it might be more constructive to turn our
resources toward combating the problem: more technical assistance, more
detailed data, and more public education.

In conducting meetings and surveys, I am a firm believer in trying to
get off on a positive note. It is very important to remember that state
and federal governments exist to serve the people and not vice versa.
State and federal agencies must be aware of local needs and problems.
Every effort should be made to mold government programs to fit the unique
conditions at the local level rather than ask local governments to work
around rigid, inflexible bureaucratic regulations.

If aerial photography is available, perhaps it can be helpful in
monitoring, but only in a limited sense. Comparison photos would be
required in order to do any good. I do not believe the expense in acquiring
those is worth it.

In monitoring a community's compliance with the NFIF, it is essential
to look both subjectively and objectively. A community's enforcement (or
lack of enforcement) of a floodplain ordinance is not always the best
indicator of effective floodplain management- programs. The City of Grand
Forks, North Dakota, provides an example. Grand Forks has a floodplain

ordinance which allows the construction of residential basements. They do
not have a basement exception. FEMA Region VIII is aware of this situation,
yet no effort has been made to CAPE the community or somehow otherwise
encourage them to come into compliance with the NFIP. The State of North
Dakota does not condone the Grand Forks ordinance, yet that city is heralded
as a model for other communities. Why? Because Grand Forks is the only
city in the state that actually levies taxes for floodplain management.
They have a one mill levy targeted specifically for that purpose. They
have a comprehensive flood fighting and emergency preparedness plan. They
have developed and are in the process of implementing a major acquisition/-
relocation plan on their own. They are not relying on outside help from
the state or federal government. So, in monitoring their activities, we
must look beyond the number of basements in the floodplain and their
less-than-perf ect ordinance. We have to look at the whole picture and
compliment them for their efforts.

Another reason to look subjectively at community floodplain management
programs is that the NFIP regulations are not always the whole answer.
Jim Considine, Illinois Division of Water Resources, notes in a paper about
floodplain management in the Chicago metropolitan area, that many communities
have adopted more stringent floodplain management regulations than the NFIP
requires as well as regulations dealing with stormwater management, wet-
lands, and soil and erosion control. He attributes this trend.to the fact
that ". . . the floodplain requirements of the NFIP are not adequate for
the metropolitan area. Communitieshave recognized the need to adopt other
regulations so as to mitigate the effects of urbanization on flood eleva-
tions." One might conclude that if a community in the metropolitan area
only has the minimum NFIP regulations adopted, then their floodplain
management program is probably not very effective. Any monitoring activity
should reveal that inadequacy.

I believe that whatever type of follow-up is needed to a monitoring
effort is what should be supplied. There is little sense in monitoring if
no actions result from it. We should strive toward providing technical
assistance and working with a community to correct any deficiencies as much
as possible instead of taking the more formal, legal action. Legal proceed-
ings can be costly and time consuming. In Illinois, for example, the
Division of Water Resources with its current staff can only conduct four
enforcement hearings a year for violations of the state floodway law.
CAPEs, as well, can be long, unproductive, time consuming affairs.

State and federal agencies should work to be as consistent as possible
with follow-up. If FEMA CAPEs a community and discovers violations, then
not only the sanctions that come with suspension should apply, but also the
state should invoke whatever penalties are appropriate (i.e., denying state
aid for flood control projects or disaster aid). The full ramifications of
federal and state executive orders relating to floodplain management should
be applied by all state and federal agencies.

Potential for flood damage along with potential for new floodplain
development should be the main criteria for selection of communities to be
monitored. The reason is obvious: it is in these communities that proper
enforcement of floodplain regulations might make a difference.

Monitoring efforts should address issues beyond regulations. The
effectiveness of floodplain regulations is intertwined with several factors:
the adequacy of the data, the level of community awareness, the status of
other local land use regulations, the existence of other structural and
nonstructural floodplain management measures. Situations in communities
are not so cut-and-dried that regulation effectiveness can be separated
from these other factors. Nor can state agencies afford the time to
separate them. With limited staff and budgets, states must concentrate on
more than just monitoring. They must provide the best service possibl 'e to
meet the overall objective of reduced flood damages. With proper planning,
all of the tools available to meet that objective (monitoring, data,
assistance, and education) can be balanced.

100

MONITORING LOCAL FLOODPLAIN REGULATIONS IN ILLINOIS

French Wetmore
Illinois Division of Water Resources

The Illinois Division of Water Resources has monitored and assisted
local regulatory programs for the last eight years. We have assisted in
Community Assistance and Program Evaluation (CAPE) meetings, we have
conducted over 60 CAPEs on behalf of the regional office, and we have
conducted over 500 community assessment site visits. Over the last f ew
years, the bulk of this work has been performed by regional planning
commissions field advisors under contract to us and funded by the State
Ass.istance,Program.

Priority-for Monitoring Work

Communities that request assistance in enforcing their ordinance are
the ones who receive top priority for an assistance or assessment visit.
Second priority for a visit are those that we have heard have regulatory
problems, either from a citizen's complaint or notice from the state
floodway regulation staff. Third priority in scheduling a visit is based
on a classification system we developed a few years ago. Every community
in the state was given a score based on factors such as population, growth,
severity of flood problem, number of flood insurance policies in force and
disaster payments. While the system is not a refined method of telling
exactly how bad a community's problem is, it definitely separates high
priority communities from low priority communities.

The Northeastern Illinois Planning Commission surveyed local officials
and asked if their field advisor could be of assistance. This survey did
help identify some communities who needed help. Some field advisors have
also used the NFIP annual reports to prioritize communities for monitoring
work. Some of the problems with the annual reports have been improved in
the last year by FEMA regional staff following up on inaccurate reports.

I have some reservations about relying on surveys and annual reports
because I do not think that they are going to tell us what we need to know.
It is hard to expect an honest answer when a federal agency asks a local
official to evaluate himself. Further, there will be more responses from
the better organized, more active and interested communities. Those who
are not doing anything will not respond. If a community reports a low
number of permits or variances, it does not mean that it is regulating
properly.. It may mean that the local officials do not bother to document
improper construction by requiring a permit or following the variance
process.

The only way to be sure that a community is requiring proper construc-
tion is to look at what has been built. This requires a site visit that
includes a tour of the floodplain and a review of office procedures. We
have developed a two-page field advisor's checklist for these site visits
-which is'similar to the one FEMA uses for CAPEs. A sample of the checklist
is included at the end of this paper.

101

Floodplain Tour

The first step in a site visit is a driving tour of the floodplain
which is usually done without the local officials. The field advisor is
free to see any part of the floodplain and he looks for any new development,
in particular filling and new buildings with basements. New buildings are
easy to spot if one looks for recent landscaping.. From the tour he can get
a feel for the area and sites to check in the permit files.

The floodplain tour could include a check of first floor elevations
but we have not done that yet,. We have worked with the firm of Sheaffer &
Roland and developed a quick and simple survey technique for obtaining
first floor elevations. This is explained in the manual, Surveying Build-
ings for Flood Hazard Mitigation (Local Assistance Series 3A). This
technique involves sighting with a hand level from a car that is located
over a known elevation such as a flood insurance study reference mark.
This method can be used to quickly-check one or two buildings.

As an alternative, one could check the elevation of every building in
the floodplain but this requires more preparation of a-reference map as
explained in the manual. The use of this hand level technique is subject
to inaccuracies of one or two feet. It is a good method to see if there is
an obvious problem but no real enforcement action should be taken until a
more accurate method is used to check the building elevation.

Office Visit

In 'many communities there has been little construction since, passage
of thea regular program ordinance and the office visit is the only way to
ensure strict regulations. The initial office visit should only include
the building official or whoever is the person responsible for the ordinance.
He is the one who must know what he is, doing. Sometimes the mayor or
manager will want to sit in and we have no problems with that. However, we
have found that often building officials are more honest about their
communities' regulatory shortcomings, particularly if they are new or are
receiving pressure from above to issue permits.

Section 4 of the Field Advisor's Checklist is the key to discerning
whether the local official knows what he is doing. The important thing on
our office visit is to ask the appropriate leading questions. For example,
the field advisor should not ask "Where is your flood insurance map?". He
should say "How do you decide if a property is affected by your floodplain
ordinance?." If the building official does not refer to a map, we know we
.have a problem.

It is important during community monitoring to keep in mind the
complexity of the NFIP to a part-time local official who has many other job
responsibilities. We try to simplify the requirements and not focus on
minutiae that may exist in the federal regulations.

Particularly in rural communities that have had little floodplain
development, we know we have an effective local system if we can answer the
following four.questions in the affirmative.

102

Is the community using the latest appropriate flood insurance
map?

Is the local official requiring permits for all development,
particularly including filling?

Are floodway development projects being forwarded to the
state floodway regulation office?

Is the community keeping records of as-built first floor
elevations?

These four questions summarize the NFIP in Illinois in a nutshell. If
the community is not doing any one of these, extra work and follow-up are
needed.

Follow-up

After the site visit, the field advisor should send a letter to the
mayor with a copy to the building official. The letter summarizes major
shortcomings and identifies specific correction measures that need to be
taken. Often we include deadlines. We also send a letter to the mayor if
we find that the local program is especially well-run.

It is very important that we devote resources necessary to follow-up
on these letters. This can be in the f orm of having the community submit
documents by the stated deadlines, telephone folow-up later on or even a
repeat site visit. Sometimes we need to have meetings with the superiors
and, in some cases, we have had public meetings with the city council or
county board. If the community is truly errant and needs pressure put on
it to reform, we have found the public meetins with media coverage to be
very successful. Even if the community is doing everything properly,
follow-up visits or telephone calls are necessary every year or so. Which
technique to use and how soon to follow-up depends on the development
potential.

103

FIELD ADVISOR'S CHECKLIST

COMMUNITY: <t_\1r, C_@ 0 \r
AS OF:

FLOOD'PROBLEM

\6-0 T*,L
Historic Floods: @4\@-@ L."A
ok
S 1z, e-y' e- a. \,z

100 Year Floodplain:
Number of residences: 0@@ecu@/ W3
Number of non-residential buildings:
Special Features:
""al P"-k C4A;Z_ 0_@ C@A@ 1J\_C_Le.S.S 4-1@,

Floodplain development potential: -,x

A s @@z L@Qw @OA

2. FLOOD DATA

Floodplain boundary map used: C",

Source(s) of 100 year flood elevations:

t,) 4' L Jc@
.@7A 011 y T@k vvl_ 4;@A Pt _z_ UN%1-0- QN-1- I

Source(s) of floodway determination: k
'dther flood studies done on the area: Q @@C_ 0-cLc_,@ S-@,j L'

3. ORDINANCE

Basis:

Local Standards that differ from DWR & NFIP requir Jents:

104

FIELD ADVISOR'S CHECKLIST
Page 2

Community: French Ford

4. DEVELOPMENT REGULATION SYSTEM
Yes Is the permit official familiar with his ordinance?
Yes Is he using the most recent version of the regulatory floodplain
maps adopted in the ordinance?

Yes Does the community ensure that all floodplain development,
including dumping and filling, is regulated? If so, how ?
Building official lives in the area and periodically checks
it for unauthorized construction or filling.

No Is there an application for permit form that notes whether the
property is in the floodplain? If so, include a copy.
Application form does not reference floodplain.

Yes Is there a permit form issued for approved projects? If so,
include a copy.

No Are possible obstructions to the flow of floodwaters being
forwarded to the Division of Water Resources for a Section 70 permit?
No floodway projects since ordinance passed. Building official knows about Section 70.

Yes Are records of as-built elevations and floodproofing
certificates for new buildings being kept? If so, how?

Locally developed form provided to banks and insurance agents,copy attached.

5. PERSONNEL
NAME PHONE

Engineer: Lightning Engineers, Inc. (consultants)

Planner: None

Attorney: Clarence Darrow
CEO: John Burn, Mayor

Zoning/Building
Official(s): Bill D. Best

105

MONITORING LOCAL FLOODPLAIN MANAGEMENT

Marguerite Whilden
Maryland Department of Natural Resources

Most critical in monitoring local floodplain management is the need to
develop a national policy including specific standards and resources with
which to monitor. Since the federal government has the largest investment
in floodplains by virtue of having underwritten billions of dollars in
insurance coverage, it would benefit it most to have an organized local
monitoring program. Most states with floodplain management programs in
force should be assisting with the monitoring; however, it is not the
states that have the most at stake.

FEMA's CAPE program provides authority and justification for the'
federal government to conduct an ongoing effort to address the proper
enforcement of floodplain regulations and improve community understanding
of the National Flood Insurance Program (NFIP). The CAPE process has been
under-utilized and in general not taken very seriously in the past. It
seems logical at this point, with a reduction in the federal flood study
effort, that an emphasis on CAPEs would be in the overall FEMA work plan.

At the state level, we appreciate the efforts of FEMA to provide
funding through the State Assistance Program and other funding programs for
the purpose of conducting CAPEs; however, these efforts have been piecemeal
with no assurance for continuation. Furthermore, these funding programs
are not addressing the need for a national policy on monitoring.

Maryland is a strong advocate of federal/state cooperation in monitor-
ing local floodplain management. In those states where flood hazard
management is a major concern, monitoring and enforcement should be a major
effort of the state resource protection function. Accordingly, Maryland
has participated in the CAPE process since its implementation in 1976,
thereby gaining valuable perspectives on how its. own natural resources
protection measures are perceived at the local level. Most importantly,
local officials have realized that there is a cooperative partnership in
existence among federal, state, and local governments that can produce
effective flood hazard management.

Once a national monitoring program has been developed, each region
should have the leeway to develop a CAPE process that meets its own needs.
The important thing to keep in mind is the goal of a CAPE: to assure that
all communities understand the NFIP and that they are meeting the minimum
requirements of the program. The achievement of this goal should be left
up to the regional level with proper support and funding from the central
office.

The National Flood Insurance Program depends largely on proper federal
policy and action. For its own benefit, FEMA should enchance the federal,
state, and local partnership. This could be in the form of a memo of
understanding to the governor of each state or director of each coordinat-
ing agency. States in turn could actively support NFIP and integrate these
regulations. into other state programs. Local municipalities and counties
can expand on this partnership and utilize national floodplain management

106

objectives and requirements to extinguish complaints of over zealous
floodplain regulations and implement an equitable resource management
program at the local levels.

Techniques

One person from.the federal region and one from the state are capable
of conducting a proper CAPE. Make arrangements beforehand to be driven
around the community by a local employee. The federal and state people can
check elevations during the first day and split up to check banks and
insurance agents on the second day. If questionable development is discover-
ed, return to the local official on the third day to resolve any concerns.
This procedure is very simple and inexpensive. Three-day CAPEs are required
in large counties.

Mail Surveys

Mail questionnaires and telephone surveys should be conducted by the
state coordinating agency. State coordinators should know their communities
and make annual recommendations to FEMA for CAPEs. Such inquiries are
useful and show a sincere state effort to help with community implementation
of the NFIP. Onsite surveys are essential by the federal/
state team and are most effective when the assistance element of the CAPE
is stressed rather than the floodplain detective end of it. Most onsite
surveys involve an informal discussion with local officials which can
reveal some very interesting and innovative activities in the community.
For the most part, we are pleasantly surprised by the level of conscientious
f loodplain management. The violations that. are discovered are generally
due to a misunderstanding of the regulations or individual property owners
who are unaware of the floodplain regulations.

Shortcuts

There are shortcuts to monitoring the extent and type of floodplain
development by involving other state and local agency officials. Often we
are made aware of pending development through the Executive Order 11988
review process. There are several other activities within local municipali-
ties and counties which rely on site inspection. We have begun working
with the Soil Conservation Service in areas with wetland protection inspec-
tors. These other inspectors should be made aware of the purpose of the
NFIP and in turn could provide information back to the state coordinating
agency. These shortcut techniques do.not satisfy the need for periodic
technical assistance and general updating on changes to the NFIP. There-
fore, the task before us should be to explore ways of conducting informative
and thorough CAPEs for less money.

Techniques in Conducting CAPEs

The best technique in conducting a CAPE is to stress the assistance
element and explain that lenders and insurance agents will also be included
to'determine if the NFIP is meeting the needs of the people for which it
was developed. A good CAPE will always remind local officials that develop-
ment is not precluded and that amendments to both the map and the regula-
tions are possible. Also, if the resources are available it is always good

107

to offer specific assistance on individual permit applications. This is a
service we- believe the state coordinating office should provide with
assistance from the FEMA region whenever possible.

Aerial Photographs

Aerial photographs can be useful for evaluating,land use changes over
a longer period of time and for large areas. Where reliable photography is
available this method could be used to determine where CAPEs are necessaryt
but considering the effort involved in evaluating and comparing aerial
photos, this time and effort might better be spent on telephone surveys or
actual field work. For the most part, aerial photography surveys do not
address the need for continuing community assistance in the federal/state
partnership. If time and ef fort is going to be spent reviewing maps, the
tax maps from the assessor's office would be a good source of information.

Objective/Subjective

In my experience with Maryland communities, those with seemingly
unimaginative floodplain management programs turn out to be some of the
most innovative and airtight enforcement programs around. My f avorite
example is Dorchestor County which - originally f ought the NFIP tooth and
nail. In a recent CAPE we learned that they not only require an elevation
reference point on the site before the permit is issued, but a county
employee actually check's the finished floor elevation before a certificate
of occupancy is issued. In the same process the county is also providing
the elevation certificate for insurance purposes. The County used-Coastal
Zone Management funding to establish elevation reference points throughout
the jurisdiction and now implements one of the more efficient flood hazard
management programs in the state.

In most cases, Maryland communities think they have a good program and
in reality they do. There are a few, however, which have developed a
capricious attitude towards floodplain management. In cases where struc-
tures are placed in floodplains without the required state permits, we are
prepared to notify the owners of their violation status and as such are
ineligible for flood insurance. This is another area where FEMA must
develop a consistent policy with regard to how they would support the state
when a �1316 determination is requested.

Follow-up

When Region III was better funded to conduct CAPEs they sent back to
the community a very thorough evaluation of the local floodplain management
program. In most cases this evaluation praised the community for the
excellent program they were implementing. In those cases where violations
are found, FEMA and the state must follow-up with the community to assure
that the community is well aware of why the development constitutes a
violation and what measures could be implemented to mitigate flood damages
at the site. In one case where the state had discovered a violation to our
floodplain encroachment law, provisions were made by the property owner to
install a sophisticated flood warning system in the underground parking
facility of the structure.

108

In general, the state tries to work with the situation to make the
construction more effective for flood hazard management and resource
protection purposes. We are not all that familiar with legal action for
removing the structure, but we are pursuing the use of �1316 for a particu-
lar project which has potential for being altered by the owner. We have
assumed that once a structure is denied flood insurance coverage it would
also be ineligible for any disaster assistance. . This is another issue we
would like to have clarified by FEMA.

Selection of Communities

Every year FEMA Region III asks the state to prepare a priority list
for CAPEs. We believe that as state coordinators we have a better idea
where the development is occurring. Ocean City is always on our priority
list. The best indicator-would be the rate of development, which can be
obtained from the number of permits. In those communities with highly
developed floodplains at the time they entered the program, we must monitor
renovation activities as well. The FEMA annual report can assist greatly
with selecting communities for CAPEs. In all cases, the state should be
included in the selection as well as the actual CAPE.

Monitoring and the Broader Issue

We should strive to integrate the NFIP regulations into existing local
programs and make the monitoring effort more of a learning process for the
local community in which they can become aware of new federal and state
programs which can enhance other local concerns. In Maryland we have used
the community meeting as a mechanism of informing local communities-of our
flood management grant program, the watershed management program, sediment
and erosion controls ' floodplain encroachment permits, emergency management
and many other state resource protection activities. While reviewing a
development in Charles County, the developer agreed to place excavation
signs in the field.and provide an area for cars during excavation.

When a national policy is developed for monitoring community floodplain
management on a regular, continuing basis, these community visits can
become the catalyst for many other environmental, social, and economic
governmental programs. It is not possible to do away with the community
visit. However, if we look at this effort in a different light the costs
involved are much easier to justify.

The National Flood Insurance Program is the only federal program that
is intimately involved in local land use issues. The NFIP has many other
unique qualities that should be capitalized upon. We could down-play the
evaluation part of a CAPE and stress the assistance part of it. Through
local floodplain management monitoring, the federal and state government
can enhance their relationships with local governments.

109

MONITORING LOCAL GOVERNMENT NFIP ADMINISTRATION

Rick Mayson
FEMA, Region IV

After more than 10 years experience in working with local governments
on floodplain management issues, I am convinced that the majority of
communities participating in the National Flood Insurance Program do not
.effectively administer floodplain management regulations. I am f urther
convinced that the most effective way not only to monitor local floodplain
management regulations, but also to provide the technical assistance
necessary to assist local governments in administering an effective program
is through an onsite, face-to-face basis.

On March 13, 1976, the -first formal Community Assistance and Program
Evaluation visit was conducted in Region IV. Since that first monitoring
visit some eight years ago, we have conducted 230 CAPEs. While the total
numbers are low in comparison to the need, we simply cannot sacrifice
quality f or quantity. Our philosophy is that when we leave a community
both we and they know all deficiencies and, more importantly, how to
correct those deficiencies and preclude future occurrence of them.

We have been able to find no short cuts that will provide us with the
quality product that I just mentioned. Rather, we have f ound that our
effort has doubled in staff time and budget costs per community from our
earlier process to the one we use currently. Each CAPE is conducted by one
planner and one engineer from our staff. We have survey equipment and a
camera, which is transported to the site and utilized to verify and record
elevations of selected buildings. The average time spent in the community
is two and one-half days -- two days with community officials and one-half
day with lenders and insurance agents. Extensive time is devoted to
preparation for the meeting and with our follow-up to correct or abrogate
deficiencies. Attached is a skeletal outline of our CAPE manual used by
all staff members and states in Region IV that conduct CAPEs through State
Assistance Program.

We have an extensive network of telephonic and written correspondence
with local governments -- usually site-specific, one-issue technical
assistance matters. We use these records along with biannual reports,
citizen complaints, insurancepolicy data, state coordinator recommendations,
and flood disaster history to determine priorities for our annual CAPE
schedule.

Our records indicate that approximately 57 percent of the communities
monitored had deficiencies in the administration of their programs.
Approximately 14 percent were considered to have major deficiencies which
required abrogation measures and extensive follow-up monitoring. I would
venture to say that each one of these communities thought that they "had a
good program" before we monitored them.

The three most frequently encountered deficiencies are inadequate.
inspections, i..e., failure to properly verify code requirements; improper
records; and excessive and improper approval of variances.

110

From our experiences we have reached the conclusion that many communi-
ties have inadequate programs due. to ignorance, inexperience or inadequate
training, but the majority of community officials simply are not committed
to the principles of sound floodplain management. Most local officials do
not believe that a serious f lood can occur in their town or county. Most
believe that our minimum standards are excessive. Most perceive the
program as an insurance mechanism. And most do not consider our regulatory
standards to be as important as their other health, safety,
and welfare codes.

Our monitoring efforts and follow-up activities emphasize the regulatory
aspects and in particular, the potential liability of the local government
as well as the possible suspension from the NFIP. We always follow up with
a letter to the chief executive of f icer of the community which states our
findings as well as identifies corrective measures that must be accomplished
within a stated time period. We also utilize the probationary status
approach for some communities with special reporting requirements that
allow follow-up monitoring without additional costly visits to the community.

I am firmly convinced that our monitoring effort is the single most
important activity of our program. Without the knowledge and commitment at
the local level we will never accomplish our goal of reducing flood damages
in this country. There really are no short cuts to this costly and time
consuming effort. It requires trained staff and adequate travel budgets.
This year three of our state coordinators are undertaking this monitoring
effort. We are hopeful that next year additional states will take on this
challenge so that our*monitoring efforts in FEMA Region IV can be doubled
by the end of Fiscal Year 1985.,

PPZPARLTION. FOR THE CAPE MEETING

I. Contact Local Official (Coordinator) to set up-meeting.,

II. Determine areas of major development.

A. obtain good base map
B. Discuss with Local Contact-

III. Send meeting letter to, CEO.

A. Date and Time
B. Where
C. Nature.-6f --- mee'ting
D. Copy local contact and State Coordinator

IV. Review Community file for problems or unique situations.

V. Review Flood Damage Prevention Ordinance for deficiencies.

A. Prepare checklist.
B., Be prepared to discuss deficiencies in mepting.-
C. Establish time limit for corrections in CAPE foilow-
up letter to conununity.

VI. Review Flood Insurance Study

A. Take copies of FIRM's and FBFW maps..

VII. Determine Preliminary sites to visit.

A. Areas of major development.
B. FIRM's and FBFW maps.
C. Recon on lst day

VIII. Secure Annual Report

A. Check number of permits and variances issued.

IX. Secure latest insurance information.

A. Number of policies in force.
B. Total coverage (whole dollars).

X. Prepare to visit banks and insurance agencies.

A. Check with official
B. Check yellow pages
C. Request list of high volume insurance agencies from CSC.
D. Select at least two banks and insurance agencies to visit.
XI. Prepare meeting agenda (optional)

XII. Call to reconfirm meeting.

112

CAPE AGENDA

1. INTRODUCTION

A. Reason for meeting

II. ADMINISTRATION AND ENFORCEMENT

A.. Procedures for enforcement
B., Floodways
C. Permits issued - since last visit.,
D. Subdivision Review
'E. Mobile homes
F. Variances
G. Ordinance Review (obtain copy)
H. Levee Policy
I. V-Zones
J. Annual Report
K. Floodproofing
L. Record Keeping
M "A" zones
N. Breakaway Walls

III. VERIFICATION OF "AS-BUILT" ELEVATIONS, V-ZONE CERTIFICATIONS,
FLOOD-PROOFING CERTIFICATIONS AND NO-RISE CERTIFICATIONS.

A. Procedure Used
B. Check records in-house (assign person).
C. Field checks
D. Bench marks available + base map.

IV. ADEQUACY OF DATA

A. Has there been alteration in flood plain (floodway)?
B. Do they have the appropriate maps (FHBM, FIRM, FBFW)?
C. Revisions required.

V. DIFFICULTIES ENCOUNTERED BY COMMUNITY

A. Suggestions

VI. CAPE QUESTIONNAIRE

VII. VISIT BANKS AND INSURANCE AGENTS

VIII. VISIT CHIEF EXECUTIVE OFFICER

T T %r cr,
C CV L 2 J7 .'ZC
A 4 C 7:%

1. DISCUSS COMMUNITY'S PROCEDURE FOR-VERIFYING

A. What type verification?

1. Certificate from registered land surveyor or engineer.
2. Verified by Building official (using BM at site)
3. Certifiedon "As-Built" plans.

B. When do they require certification?

1. Immediately after lowest floor is completed?
2. Prior to issuance of Certificate of Occupancy?

C. if later, suggest.a time period be added to their ordinance.

1. For example, Region IV's.Sample Ordinance.

II. REVIEW PERMIT FILES FOR VERIFICATION

A. Do the files'cor@tain documentation?

1. If so, select a few sites to verify.
If not, select a number of sites to verify.
a. Review community ordinance and 44 CFR,
60.3(b)(5) with community officials.

III. FIELD CHECK OF "AS-BUILT" ELEVATIONS

A. Select projects under construction.
B. Verify others that have been verified.
C. Utilize local bench marks.
D. Field Surevy'Report.

IV. ANCHORING CERTIFICATIONS (V-ZONES ONLY)

A. Is documentation in file?
1. If not, review with local officials the section in
their ordinance and 44 CFR, 60.3(e)(4).
B. Mangroves and Sand Dunes
C. Breakaway Walls

V. FLOOD-PROOFING CERTIFICATIONS

A. Is documentation in file?
1. If not, re view with local officials the section
in their ordinance and 44 CFR, 60.3(c)(4).
V1. FLOODWAY "NO-RISE" CERTIFICATION
A. is documentation in file?
1. If not, review with local officials the section in
their ordinance and 44 CFR, 60.3(d)(3).

VII. DOCUMENT NON-COMPLIANCE

A. Pictures
B. Names and Addresses
114 C. Type of Violation

FIELD SURVEY REPORT

Name of owner (if available):

Address of Structure:

Type of Structure:

Provide intersecting streets on either side:

Distance from edge of street to front of structure:

.Flood Zone:

Base Flood Elevation:

Actual Lowest- Floor Elevation:

If in a V-Zone or floodway, does it meet FEMA constrluctionstandards

if not, explain:

Development Permit

Date of Issue:

(PICTURE)

FEKA REGION VII EXPERIENCE WITH
COMMUNITY ASSISTANCE AND PROGRAM EVALUATION

Patricia K. Stahlschmidt
Federal Emergemcy Management Agency

The purpose of the Community Assistance and Program Evaluation (CAPE)
program is both to provide technical assistance to the communities partici-
pating in the National Flood Insurance Program (NFIP) and to evaluate the
floodplain management enforcement efforts of these communities. Due to
time and staff constraints, Region VII has focused its CAPE activities on
regular program communities. The Region's basic goal has been to CAPE each
.of these at least once every five years.

This paper focuses on the method developed by Region VII to select and
screen CAPE candidates. By following the procedures described below, the
Region attempts to gain maximum benefit from its CAPE program. Another
important advantage to these procedures is that they allow the Region to
identify potential problem communities before serious violations occur.

Identification and Selection of CAPE Candidates

In FY 1982, Region VII developed a method for selecting communities to
be CAPEd that fiscal year. The method assigned points to communities based
on the five factors shown below. Those communities having the greatest
number of points were selected in this manner. The remaining CAPEs were
selected on a discretionary basis throughout the year, as the need arose.
The five factors and their point values are:

POINT
FACTOR VALUE

Development pressure 5

Large percentage of 4
variances to per-
mits

Five years with no 3
CAPE or over one
year from conver-
sion

No annual reports 2
received for the
last three years

Travel savings and I
efficiency

After using this priority ranking system for two consecutive years certain
problems emerged. The principal problems involved the difficulty in

116

identifying dev elopment pressure, and particularly development potential in
the flood hazard areas; variances were not always recorded or accurately
reported; and, using the date of the last CAPE as a factor lead the Region
to select small communities which had little floodplain activity or need
for a CAPE.

In FY 1984, Region VII revised its CAPE selection criteria to provide
more flexibility and a less quantitative approach to CAPE selection. The
Region determined that any community meeting one or more of the following
criteria would be considered a potential CAPE candidate.

1. The community's annual report, or the absence of one, was the
principal factor used to select CAPE candidates. Any community
meeting the following conditions was automatically reviewed
by the CCO as a possible CAPE candidate:

9 No annual report received for the past two reporting
periods.

e Any community that requested assistance on the annual
report.

* Any community that granted a suspect number of variances.

* Any community that indicated that floodplain development
was occurring.

2. In addition to annual report data, and for those years when
annual reports are not received, the following criteria would
be used for selection of possible CAPE candidates:

e Floodplain development pressure or potential for development
was judged using the best available information such as
personal knowledge, information from another federal
agency (HUD or EPA), or information obtained from the
state coordinator. Communities exhibiting floodplain
development pressure or the potential for such development
were given one ranking point.

e Number of NFIP policies. Any community having over ten
flood insurance policies was given one ranking point.
Insurance policies are an excellent indicator of floodplain
activity or flooding problems.

* Size of the SFHA. Any community with a special flood
hazard area over 25 percent of the total area was given
one ranking point. If the SPHA was in an area suitable
for future development a point was also given for develop-
ment potential.

a Number of structures in the SFHA. Any community having
over 10 percent of its structures in the floodplain was
given one ranking point.

117

e Date of last CAPE. Any community that had not had a CAPE
or had not-been reviewed f or a CAPE within the last five
years was given one ranking point. The Region VII master
CAPE list assure& that no community was completely over-
looked, regardless of the total number of ranking points.

Using the system described above, Region VII identified 224 possible
CAPE candidates. Since available staff and travel resources normally limit
Region VII to approximately 70 CAPEs each year, the actual FY 1984 CAPE
Plan was developed through the telephone screening process described below.

CAPE Telephone Screening

CAPE screening calls allowed the staff to contact all of the 224
communities that the CAPE Priority Ranking System indicated to be in need
of a CAPE visit. The specific purpose of the calls was to determine which
communities were actually in, need of a CAPE visit, and which communities
needed only a phone contact and possibly a follow-up letter to serve as a
CAPE contact. Where necessary additional information on communities was
obtained from the state coordinator, a regional planning commission, or the
CCO's own personal knowledge of the community. Specific screening procedures
and a copy of an actual screening call memo are attached.

The CAPE screening effort was conducted during the first quarter of
FY 1984. The telephone screening successfully met a number of objectives
and was felt to be an extremely worthwhile effort. Specif ically, the
screening effort accomplished the following:

I.. A more productive FY 1984 CAPE Plan was developed by allowing
the staff to screen out the lower priority CAPEs and communi-
ties not found to be in need of a CAPE.

2. Sixty-six communities were identified that were in need of a
CAPE contact but that did not warrant an actual CAPE visit.
These were generally direct conversion communities with
little or no floodplain development activity.

3. Nine larger communities were identified in which on going
technical assistance or other contact replaced the need for a
CAPE visit.

4. A FY 1985 CAPE Plan was also developed. Sixty-three of the
communities screened were found to be in need of a CAPE
within the next two years, but could not be accommodated in
the FY 1984 Plan.

5. Forty-one communities screened were determined not to be in
need of assistance at this time.

6. The screening effort allowed the staff to follow-up on all
requests for assistance on the 1982 Annual Reports.

The major benefit of the screening effort was that it allowed the
identification of the areas of greatest need and the direction of limited
staff resources to those areas. In addition, the screening effort enabled

118

the staf f to annually contact if not actually visit 20 percent of its
Regular Program communities f or CAPE purposes. Actually, in this f irst
year, 224 of the Region's 541 Regular Program communities that have a FIRM
were screened (41 percent) . This ef fort cleared the backlog of those
communities that had been in the Regular Program at least five years and
had never had a CAPE contact. Future screening efforts are expected to be
somewhat less extensive.

Conclusion

Region VII has used and refined the procedures for identifying and
selecting CAPE candidates, as described in the first part of this report,
for several years. This has proven to be a very workable and productive
system of CAPE selection. Admittedly there are some problems with obtaining
accurate and reliable data, such as when trying to identify potential
floodplain development pressure in a community,, but such problems exist
with any system of data collection. The data used in this CAPE selection
process is easily updated on an annual basis, and the system ensures that
no community is overlooked in the CAPE selection process. Region VII feels
that its selection of CAPE candidates is defensible, systematic and sound.

The telephone screening process is new and has not been evaluated over
a long period of time. However, this process also appears to be quite
successful and definitely fills a need. Neither Region VII nor any other
FEKA region can continue to CAPE Regular Program communities at the same
rate as in the past. The telephone screening process provided a workable
and effective method of reaching even the smallest community. Unlike a
mail survey, the telephone screening assured a 100 percent return rate from
community contacts. The exchange of information in a telephone conversation
also better reveals the true capability and understanding of floodplain
regulations among locAl officials, as indicated in the sample screening
report attached to this paper. With the continuing and inevitable staff
and travel limitations faced by each FEKA region it appears that telephone
screening could be an important part of.any CAPE program.

119

PROCEDURES FOR SCREENING

The purpose of the CAPE screening is to narrow our number of potential CAPE
candidates to a manageable workload by screening out those communities which are not
now in need of a CAPE visit. The Annual Report Data Sheets indicate that 212 of the
region's 542 Regular Program CAPE candidates (approximately 40%) meet one or more of
the fol'lowing criteria and are in need of a screening call. (Communities which have
had a recent CAPE were not Included.in the screening list.)

1. Five or more years since entry in the Regular Program and/or date of last CAPE.

2. No Annual Report received for the past two years.

3. Community request for assistance.

4. Questionable number of variances granted.

5. Number of permits, policies or size of SFHA indicates that flood plain develop-
ment may be occurring.

A CAPE Screening Report (copy attached) must be completed for each community on
the screening list. The report form is fairly open-ended and is designed to be flex-
ible. It is essential that each CCO make adequate comments on this report for it to
be useful. At a minimum, each'community contact should cover the following points:

1. Does the community have and know how to use the FIRM and Floodway Map?

2. What is the general use of land in the flood plain at this time?

3. Does the community have current development activity in the SFHA?.

4. Does the community have development potential in the SFHA?

5. Does the community have a flood plain development permit system in force?

6. Discuss the reason for the screening call (as shown on the report) and indicate
how this problem can be resolved.

Each Screening Report should end with a recommended action. Either an FY-84
CAPE is needed, an FY-85 CAPE is needed, other technical assistance can resolve the
problem (explain), the problem has been resolved with the screening call, no problem
actually existed and no CAPE is needed, etc. This screening will hopefully allow us
to identify those communities which are in the Regular Program but have no flood
plain development and therefore do not warrant a CAPE visit even though the community
may not have enforcement procedures in place. We will follow-up with these communi-
ties by sending a standard letter advising them to contact this office for assistance
if it should ever experience flood plain development. By phoning and sending this
follow-up letter, the Regional Office will be able to demonstrate CAPE related con-
tact with communities at least once every five years without spending our limited
CAPE time on unproductive vi6its.

August, 1983
Patricia Stahlschmidt
120

YI-04 CAM UUMOINU HEFUNT

State
v

Signer of Most Recent Annual Report:
P @" " a 64 -8 -3
I-Name) I (Title) (Date)

Phone Contact for CAPE Screening:
Name Date le P
Title Phone 1/9 539 403

&6Jr17
Reasoh for Screening Call:
PE-41 /10, -1-@r - 6- /.
V 4OF

Findings from Call:
sr*4 "

ew-

lei
O'L@& Other
iY--84 PE NFeded.- Yets)(:L x (see comments)
Comments /Recommended Action:
7Z4

W101@7- 1z @j tla",
- @fl

121
CCO

THE CAPE PROCESS IN FEMA REGION III

Walter Pierson
FEMA Region III

The CAPE process has been very useful in assessing the degree of
activity at the local level. Because of travel fund limitations, Region III
of FEMA will this year be completing only a small fraction of what we have
during the past, as far as CAPEs held in the f ield. We will also be
experimenting with a questionnaire-telephone contact CAPE.. Another techni-
que could be a straight "fill in the blanks" questionnaire, relating to
compliance with the regulations.

We do not have any specific experience with mail questionnaires or
telephone surveys. As far as onsite surveys being essential, we will have
to reserve judgment until we do have experience with the former two items.
If the annual reports are any indication of effectiveness of mail question-
naires, we are probably in trouble. It.seems that each respondent interprets
those. reports in a different way, and we have results that are not consis-
tent. In the majority of the communities in Region III, the local officials
usually do not have any idea of how many structures are located on the
floodplain. The estimates vary widely, even between officials in the same
community.

It-does not appear that there are any effective Ahortcuts to conducting
community surveys. Past CAPEs reveal that community officials are not
always aware of the extent of the floodplain as shown on FEMA maps, nor are
they aware of the construction that. is taking place on the floodplain in
their communities. They were almost never aware of filling that has taken
place.

The first question in any survey would be "How many-permits have been
issued in the floodplain area since last CAPE or entry into the regular
program?" In some communities these permits are annotated and kept in good
order. In many communities it may be necessary to search through volumes
of material to try to get to those permits which are pertinent. In many
cases it is easier to ride the floodplain and note the structures that
appear to be fairly new and go back and ask for the permits on those. It
is also a good idea to ask the community official about verification of
first floor elevations once the structure is completed. He/she should also
be queried as to the internal monitoring program to detect non permitted
construction or modifications on previously permitted buildings. The key
to the CAPE program, as well as to the National Flood Insurance Program, is
the building permit system. An elementary question that we always ask the
community officials is "Do you have a copy of your floodplain management
ordinance?" A significant percentage do not, and we are usually prepared
to supply them with a copy. The same holds true for the study and associ-
ated floodplain maps provided by FEMA.

In Region III we have never had the opportunity to use aerial photo-
graphs for monitoring activities. It has some interesting possibilities.
Many of the studies we have conducted have included aerial photogrammetry.
It may be possible to retrieve some of these photographs from the contractor
or the repository, and with some training and some equipment purchases we

122

would be able to orient ourselves to the ground in various communities to
at least determine which construction has been performed since the photo-
graphs were taken. Obviously this takes 'a trip to the field or a second
set of aerial photographs. At a time when we are very short of not only
travel funds but study funds, it does not appear that the agency will be
prepared to spend money on hundreds of miles of aerial photography to
assist in a monitoring phase; nevertheless, it is undoubtedly a good idea,
the question being can we afford to do it.

Since the inception of the CAPE program, we have always made surveys
in the field. This included not only a windshield survey to see that all
structures have been permitted and appear to be elevated, but we have gone
so far as to purchase a surveyor's level and associated paraphernalia so
that we can actually check elevations in the field. This equipment has
been used many times in the region to good effect. Oftentimes the community
that thinks it has a good program f inds out as a result of the CAPE that
they do not have the control that they thought. It is a premise of the
CAPE program that we cannot take anything for granted.

123

PART V: RECOMMENDATIONS

Part V is based upon the issue papers, workshop presentations,
and follow-up discussions.

125

Overall Recommendations

hat are-the most promising approaches for
Given budget limita lons, w
answering immediate'questions and provid ing a solid-l-ong-term
data base for evaluation of individual floodplain management
techniques and community programs?

(1) Post-flood surveys. Floods provide a "laboratory" for
testing the effectiveness of various floodplain management
techniques. After floods,selected *field surveys should be
conducted for particular conditions and types of communities to
determine.:

(a) The precise nature of the flood damages (e.g. water
damage alone due*to depth of inundation, collapse of
basement, destruction of wiring, pollution of well,
erosion, etc.);

(b) The structures and activities to which damages have
been sustained (i.e., public roads, sewage treatment,
water supply, other infrastructure; private,
commercial, and non-commercial uses);

(c) The protection or mitigation measures in place at the
site (levee, seawal '1, elevated structure), level of
'Protection (100-year event), degree of maintenance,
etc.;

(d) The particular.degree and type of risk (alluvial fan,
floodway, high velocity flow).

Small teams of experts, modelled on and working with the
Interagency Flood Hazard Mitigation teams, should go into
stricken areas and gather information. Efforts to determine
effectiveness of techniques could perhaps best focus initially
on areas such as the Susquehanna River Basin for which
considerable "baseline" data already exist about numbers and
types of structures, their condition, mitigation measures, and
date of adoption. States could assist in such post-disaster
surveys under Section 406 of the Disaster Relief Act of 1974.
Comparisons should be made of disaster assistance versus flood
insurance claims data. Industries that have suffered losses
could be asked to make estimates of physical damage, loss of
inventory, loss of production, and length of down time.

Follow-up assessments both one year and five years later
should be conducted for some of these areas to determine how
disaster and insurance funds were ultimately used, the extent
to which mitigation measures were actually incorporated in
reconstruction, and whether such mitigation measures reduced
losses during subsequent flooding.

126

(2) Modelling and Laboratory Testing Techniques. Actual
S testing of various- flood loss reduction techniques by modelling
and by laboratory testing (e.g. flooding buildings with
particular designs) should be enhanced. Models.and scenarios
could be used more extensively to predict potential losses.
Consultants marketing various flood loss reduction systems
should be encouraged or required to test the effectiveness of
these systems.

(3) Refinement of Data Gathering and Analysis as Part of
FEMA's Flood Insurance and Disaster Assistance Prog .rams.
Refinements are needed in the types of data gathered on the
flood insurance policy form, on flood insurance claims,
disaster assistance claims and the community bi-annual
reports. All data should be formated and stored in a
11compatible" form to facilitate analysis. Additional data such
as population growth should also be included.

(4) Combining Telephone Surveys, Questionnaires and Onsite
Visits for Monitoring Communities. Additional onsite
monitoring of selected communities is needed for enforcement of
NFIP and state standards, to convince communities that
regulations have ffteeth" and to determine the effec.tiveness of
programs in actually reducing flood losses. Priorities should
be set for onsite studies of communities based upon numbers of
insurance policies, insurance claims, disaster claims,
population growth, area in.the flood plain and other factors.

The costs of onsite monitoring could be reduced not only
through careful preliminary screening of communities but also
b y

(a) Using telephone surveys and written questionnaires to
gather a portion of the needed information;

(b) Focusing on post-disaster situations in which federal
and-state staff,are usually already heavily involved;

(c) Utilizing regional agencies and states to conduct
monitoring (greater familiarity with local conditions,
lower travel costs); and

(d) Use of time series air photos, which can be used to
locate new development.

Although it may be cost effective to combine community
monitoring and technical assistance as has been done in the
past, arguments can be made in favor of separating these
functions. FEMA is often in the best position to monitor and
enforce NFIP requirements; states and other federal agencies
are often in the best position to provide planning, ordinance
drafting, and engineering assistance. If monitoring and
technical assistance are to be separated, technical assistance
may best be handled through a multiagency effort involving

127

federal, regional, and state governments and including FEMA,
the Corps of Engineers, the TVA, and the.SCS.

Gathering and Analyzing Data

FEM A is perhaps in the best position to coordinate and
sponsor efforts to determine the effectiveness of community
programs and individual techniques although other federal
agencies, the states, and universities should assist such
efforts and in some instances should undertake the actual
analysis:

(1) Post-disaster assessments of communities and
individual techniques may best be undertaken by FEMA
with the assistance of the Corps, the states and
consultants since FEMA has been assigned the lead in
the federal post disaster team effort and since it
administers the major federal disaster assistance
program and the NFIP.

(2) Laboratory testing of techniques may best be
undertaken by the Corps, private consultants and
universities.

(3) Monitoring communities for enforcement purposes may
best be undertaken by FEMA, working.with the states
and other agencies.

(4) Monitoring of communities to determine the broader
effectiveness of techniques may be undertaken by
universities the TVA, the Corps or private consultants
with the support and sponsorship of FEMA.

(5) The gathering, storage and analysis (for certain
purposes) of disaster claim data, flood insurance
data, community annual reports and Section 1362 data
should be undertaken primarily by FEMA. Independent
analyses may also be helpful.

Data Needs

Data gathering and analysis should be sufficiently focused
to address specific management needs while also creating a
long-term analytical base suitable for answering other
questions. Post flood information and on-the-ground field
evaluations are a necessary component of each of the following
.issu,es.

(1) Levees. How serious are losses behind levees due to
poor internal drainage? Overtopping? Seepage?
Inadequate maintenance? Do 25, 50 or 106-year levees
reduce damages sufficiently to justify decreased
insurance rates or special management policies?

126

Lack of even elementary "effectiveness" data gave rise
to fragmented recommendation's of the National Academy
of Sciences Committee on Levee.Policy in 1979 and to
highly divergent policies for even neighboring
states: Wisconsin gives.virtually no credit for
levees in its floodplain regulations while Illinois
gives substantial credit.

Need for -Data. Rate-setting for the NFIP, regulatory
standard-: 7etting and building design criteria at
federal, state and local levels all would benefit from
additional data on the performance of levees..

Data Gathering. Flood insurance and disaster
assistance data should be analyzed on a selected basis.
for areas behind particular levees after floods of
various macnitudes.

(2) Unique and High Risk Area Flood Problems. It was
assumed in the late 1960s that most flood damage was
due to clear water flooding of.limited duration with
limited velocities and relatively stable channels.
Flood stage, therefore, became the major damage factor
considered in mapping, regulatory standard-setting,
and building design. However, it is now clear that
other damage, factors are important, if not paramount,
for alluv'ial fans, mudfloods, lake flooding, combined
coastal erosion/floodingo subsidence, liquefaction,
areas below unsafe dams and behind unsafe levees, ice
jams and high gradient streams. How much develooment
is located in these areas? How much flood insur@nce
versus disaster-assistance is presently being spent on
such areas? How effective (or ineffective) have
existing regulatory guidelines or building practices
been for these areas?

Need for Data. Mapping criteria and priorities should
be established at federal, state and local levels.
Improvement should be made in rate-setting for flood
insurance; redrafting 406 planning criteria for
states; and establishing upgraded regulatory and
building code standards.

Data Gathering. Reports of post-disaster teams should
be analyzed to determine the percentage of losses from
unique or high risk area problems. These data should
be compared with flood,insurance and disaster
assistance data for these areas including premium
versus loss data. New post-disaster assessments
should be carried out on the ground by teams of
experts. Refinements should be made in flood
insurance application forms and claim forms to help
identify high-risk area losses. Refinements in
disaster assistance claims are also needed to identify
source-s of the loss.
129

(3) Stormwater Management Versus "Flooding". What
percentage of flood problems are, in fact, stormwater
management problems? How effective are existing
designs for stormwater management?

Need for Data. Flood insurance rate-setting for areas
outside of mapped floodplains; flood mapping
priorities and criteria,; stormwater management
regulatory and planning guidelines at federal, state,
local levels; and technical assistance to communities
all need. improved data..

Data Gathering. Flood insurance and disaster
assistance should be analyzed and compared for
communities suffering flood losses. Insurance policy
data and various types of claim and flood loss data
should be aggregated on a community-wide basis (as has
been done already on a limited basis) for both
unmapped and mapped hazard areas. Field
investigations are needed to determine the percentage
of losses due to drainage, and the effectiveness of
various drainage planning and management strategies.

(4) Relative Effectiveness of Nonstructural Floodplain
.Management Approaches. How effective are individual
nonstructural floodplain management techniques in
reducing flood losses? For example, how much is
structural floodproofing actually reducing flood
damages when a flood occurs, given the maintenance
problems with.such an approach and recent findings
that it is very difficult to make a large structure
watertight if flooding persists for more than a few
hours? What measure of protection is provided over a
20, 50, or 100-year period by elevation on pilings in
areas of erosion, high winds, or natural deteriorating
forces such as termi'tes, salt, water or "dry rot"'?
Does elevation on fill in riverine and coastal flood
fringe areas have such built-in safety factors (e.g.,
no deterioration over time, often limited damages when
the design flood is exceeded) that favorable insurance
rates should be provided? How great are the losses to
public infrastructure (roads, sewer, water supply)
when flooding occurs for an area with nonstructurally
protected individual structures?

Need for Data. Establishing flood insurance rates;
establishing and upgrading regulatory guidelines at
state, federal and local levels; providing technical
assistance to communities and private individuals; and
the design of structures and uses all would benefit
from improved and expanded data.

130

Data Gathering. Post flood surveys, modelling and
laboratory testing are needed for individual
techniques under particular flood stage, velocity,
erosion and other conditions. Maintenance and
inherent safety factors for multihazards and the full
range of anticipated flood events should be
considered. Flood insurance applications and flood
insurance claim forms as well as disaster assistance
forms could be amended to require additional data.
This would facilitate future broader analysis.

(5) Flood Insurance Premiums Versus Losses. What premiums
have been paid and what losses have occurred for
particular types of uses, with particular levels of
flood protection, in particular setting's?
Considerable analysis is already underway but
refinements are needed.

Need for Data. Additional data would assist in
refining flood insurance rates; upgrading regulatory
and building design standards; guidance and technical
assistance to individuals, and communities; and
targeting communities for federal or state technical
assistance.

Data Gathering. Flood insurance policies, insurance
claims and disaster assistance claims could be more
effectively used for analytical purposes if
refinements were made in insurance applications,
insurance claims, and disaster assistance forms to
more specifically identify the nature of hazard,
nature of loss, type of use, and protection measures.

(6) Community Enforcement. To what extent are communities
administering and enforcing the standards of the
NFIP? What factors have led to such enforcement or
lack of enforcement?

Need for Data. Data would benefit enforcement actions
by FEMA and the states; and technical'assistance and
training and education by the states, and federal
agencies.

Data-Gathering. Additional evaluation is needed of
flood.insurance claims, insurance policies, disaster
assistance claims, community reports, permits,
variances, and map amendments. More detailed "on
site" evaluations are also needed. These could be
conducted by states as well as federal agencies.

(7) Effectiveness of Community Loss Reduction Measures.
How effective have community floodplain management
programs been in reducing losses to new buildings and

131

infrastructure? To existing buildings and infrastructure?
What approaches have been most cost-effective individually or
in combination? What factors have led to effective community
approaches?

Need for Data. Additional data would guide
policy-makers at federal, state and local levels in
selecting particular techniques or combinations of
techniques; and help federal.and state agencies design
and carry out technical assistance and training and
education programs.

Data Gathering. Detailed examination is needed of
overall community programs, particularly in a
post-flood context. Such evaluations can be
accomplished through a combination of on-site surveys,
questionnaires, telephone surveys; and analysis of
flood insurance and disaster assistance data.

(8) Dams. Given the high rates of sedimentation,
increased runoff, possible seismic activity, and
growing maintenance problems in many areas of the
country, what are the actual benefits of dams when
projected over a 200- or 300-year period? Is the
enhanced development below dams placed at higher risk
after 75 or 100 years due to sedimentation and natural
deterioration of the structure? Could such
development occur initially at upland sites, and, if
so, what are the net costs on benefits of relocation
outside of the floodplain in contrast with protection
by dams?

Need for Data. Design criteria for construction and
maintenance of dams; implementation of cost-benefit
analyses for dams; comparisons of techniques; and
evaluation of federal/state dam safety programs all
would benefit from expanded data.

Data Gathering. Post-flood damage estimates should be
compared with initial projections and cost/benefit
ratios. Modelling should be.done for sedimentation,
earthquakes, and areas subject to inundation by dam
failures.

(9) Subsidence and Sea Level Rise. Given the future high
rates of sea level rise predicted by some experts,
what will the effects be over the next 100 years on
coastal flood damages? More specifically, how will
such a rise affect the costs and benefits of groins,
levees, sea wallsI beach nourishment, evacuation
planning and other techniques?

132

Need for Data. Additional data would aid in the
preparation of evacuation plans; revision of
regulatory criteria and guidelines for coastal
construction; calculation of erosion rates; and the
conduct of cost-benefit analyses for flood control
measures.

Data Gathering. Flood losses over the last 100 years
for various areas should be compared, and different
scenarios should be modelled.

133

NATURAL HAZARDS RESEARCH AND APPLICATIONS

INFORMATION CENTER SPECIAL PUBLICATIONS

The Special Publications series was created in 1981 to accommodate
the publication of studies and analyses that deserve to be made available
to the general public, but do not fit into the formats of other series at
the Information Center, specifically, monographs and working papers.
Special Publications may be too long or too short for other series, or
different in intent and purpose, but they are of interest to assorted
researchers and practitioners. Copies are variously priced, as indicated
below, and available from the Natural Hazards Research and Applications
Information Center, Campus Box 482., University of Colorado, Boulder, CO
80309. Prices listed i.nclude the costs of.mailing.

1 Population and Housing in Special Studies Zones. Claudia Grow and
Risa Palm. 1981. 51 pp. $3.00.

.2* Regulation of Flood Hazard Areas to Reduce Flood Losses, Volume 3.
Uon _Kusler. .1982. 300 pp. $8.00.

3* Strengthening State Floodplain Management, Appendix A to Volume 3.
Patricia A. Bloomgren. 1982. 123 pp. $8.00.

4* Innovation in Local Floodplain Management, Appendix B to Volume 3.
Jon Kusler. 1982. 262 pp. $8.00.

*SP #2, SP #3, and SP #4 can be purchased as a set for $21.00.

5 Floodplain Regulations and the Courts 1970-1981. Jon Kusler.
1982. 51 pp. $5.00.

6 The Human Environment: Penultimate Problems of Survival.
RoEe-rtW. Kates. Gustavson M-e-m-5-r-ia-T-Lecture. IT8-3.48 pp. $3.50.

7 Preventing Coastal Flood Disasters: The Role of the States and
Federal Response. Proceedings of a National Symposium, Ocean City,
Maryland, May 23-25, 1983. 386 pp. $10.00.

8 Addresses, Topics of Interest, and Geographic Distribution of
rr-ofessors Working on Landslides in the United States.
Earl E. Brabb and Ann FitzSimmons. 1984. 33 pp. @T.50.

9 Improving the Effectiveness of Floodplain Management in Western
State High-Risk Areas: Alluvial Fans, Mudflows, Mud Floods.
T-roceedings of a Workshop, Palm Springs, California, February 15-169
1984. 97 pp. $7.00.

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