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		<mainTitle nfc="0"><title>Evaluating the effectiveness of floodplain management techniques and community programs</title>:<titleExt>proceedings of a seminar conducted April 30-May 1, 1984</titleExt>/<respStmt>by the Tennessee Valley Authority in cooperation the Interagency Task Force on Floodplain Management.</respStmt></mainTitle>
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	<authorStmt>
		<corpAuthor><name>University of Colorado, Boulder.</name><subName>Natural Hazards Research and Applications Information Center.</subName></corpAuthor>
		<corpAuthor><name>Tennessee Valley Authority.</name></corpAuthor>
		<corpAuthor><name type="jurisdiction">United States.</name><subName>Interagency Task Force on Floodplain Management.</subName></corpAuthor>
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	<imprint><pubPlace>Boulder, Colo.</pubPlace>:<pubName>Natural Hazards Research and Applications Information Center, University of Colorado</pubName>,<pubDate>1985.</pubDate></imprint>
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			<subject cat="top">Floodplains.</subject>
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<pb n="1" />

                                         COASTAL ZONE
                                        INFORMATION CENTER

                                                    COASTAL ZONE
                                                    INFORMATION CENTER

                              Natural Hazards  Research
                                     and   Applications
                                    Information Center

         GB
         562
          .E9
         1985
<pb n="2" />

                                          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

                                                     by

                                       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
<pb n="3" />
<pb n="4" />

                                                  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
<pb n="5" />

               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.

                                                  iv
<pb n="6" />

                                         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

                                                v
<pb n="7" />

                                                 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

                                                          vi
<pb n="8" />

                         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
<pb n="9" />

                                           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
<pb n="10" />

                                   PART I: SUMMARY AND OVERVIEW

        Part I is based upon.the issue papers, workshop presentations and follow-up
        discussions with Interagency Task Force members.
<pb n="11" />

                          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.

         2
<pb n="12" />

                  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?

                                                                             3
<pb n="13" />

              (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

         4
<pb n="14" />

                  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.

                                                                               5
<pb n="15" />

           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.
<pb n="16" />

                                           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.

                                                                                         7
<pb n="17" />

                                                      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
<pb n="18" />

                                   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;

                                                                                           9
<pb n="19" />

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

                           (c)  Alternative structural measures for protection against
                                flooding; and                                                         4

                           (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.

           10
<pb n="20" />

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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).

          12
<pb n="22" />

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

                                                                                A specific strVctur,

                                                              (Jae&amp;, 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
                                                    '   &amp;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 &amp;g7i:n
                                                                                                              di           tif II., ItIT, MPE, @Lc.

                                                                                                                                                          am

                                                                                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)

                                                                                                                                                                                        13
<pb n="23" />

                                                                                             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

                                       3                                                                                                     3

                                       2r-                                                                                                 2 6, We"'
                                                                                                                               F H F           lomporary
                                       0                                                                                                         Closures
                                       0             5             to            15            20           25            30
                                                      EVENT AT FIRST FLOOR (EXCEEDANCE INTERVAL,YEARS)

                                                                                              (Johnson and Davis, 1982)

                 14
<pb n="24" />

                   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).

                                                                                            15
<pb n="25" />

                                                                                                                                    9T

                                                              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)

                                                                                                  17
<pb n="27" />

                                               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)

          18
<pb n="28" />

                    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.

                                                                                                19
<pb n="29" />

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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 &amp; 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).

                                                                                        21
<pb n="31" />

                      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.

          22
<pb n="32" />

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<pb n="33" />

                             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
                                                                                                                 r
                                                                                                                            opt'n
                                                                                                                            B

                                                                                                                              Sur.
                                                                                                                    Floodlon
                                                                                                                    Prem    um
                                                                                                                    $7,90

                                230-067 0 - 776

                  24
<pb n="34" />

                           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

                                                                                                         25
<pb n="35" />

                     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,

          26
<pb n="36" />

                                          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
<pb n="37" />

                                                                        Zml
<pb n="38" />

               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.

                                                                                              29
<pb n="39" />

               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.

         30
<pb n="40" />

                                                      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.

                                                                                                         31
<pb n="41" />

                 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.

           32
<pb n="42" />

               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&amp;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.

                                                                                                 33
<pb n="43" />

                            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.

                                                                                        35
<pb n="44" />

                                                       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

          36
<pb n="45" />

                                        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?

                                                                                                 37
<pb n="46" />

                                     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)

          38
<pb n="47" />

                   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

                                                                                          39
<pb n="48" />

                 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.

          40
<pb n="49" />

                   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.

                                                                                           41
<pb n="50" />

                      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).

           42
<pb n="51" />

              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.

                                                                                            43
<pb n="52" />

                  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.

           44
<pb n="53" />

              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.

                                                                                             45
<pb n="54" />

         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

         46
<pb n="55" />

                   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&amp; 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.

                                                                                            47
<pb n="56" />

                 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.

           48
<pb n="57" />

              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.

                                                                                          49
<pb n="58" />

                      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

          50
<pb n="59" />

                                                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 &amp; 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
<pb n="60" />

                                                                     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?

                52
<pb n="61" />

                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

                                                                                                                               53
<pb n="62" />

                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.

          54
<pb n="63" />

                   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?

                                                                                           55
<pb n="64" />

                                              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

               56
<pb n="65" />

                                                 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.

                                                                                                 57
<pb n="66" />

                 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.

           58
<pb n="67" />

             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.

                                                                                      59
<pb n="68" />

                             PART IV: SPEAKERS' PAPERS     EFFECTIVENESS OF

                                          INDIVIDUAL TECHNIQUES

                                                                                       61
<pb n="69" />

                               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

           62
<pb n="70" />

              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.

                                                                                         63
<pb n="71" />

                            40,w
                                                                                MAXIMUM PRACTICAL EVACUATION (MPE)'

                            30-

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

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

                         w

                             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

                                                       70

                                                       0

                                                       40

                                                       30
                                                                Automated          system
                                                       20

                                                       10
                                               Ic

                                                            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
                                ..........

              64
<pb n="72" />

                                   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.

                                                                                          65
<pb n="73" />

                       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.

           66
<pb n="74" />

                                  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-

                                                                                         67
<pb n="75" />

                 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

           68
<pb n="76" />

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

                                                                                       69
<pb n="77" />

                                       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

           70
<pb n="78" />

              firm of Sheaffer &amp; 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 &amp; 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.

                                                                                        71
<pb n="79" />

                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.

          72
<pb n="80" />

                                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

                       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
<pb n="81" />

                     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

          74
<pb n="82" />

              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.

                                                                                           75
<pb n="83" />

                                   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.

          76
<pb n="84" />

                          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

                                                                                           77
<pb n="85" />

                     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.

          78
<pb n="86" />

                    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.

                                                                                             79
<pb n="87" />

                                            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
<pb n="88" />

                                                 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
<pb n="89" />

                       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

           82
<pb n="90" />

              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.

                                                                                             83
<pb n="91" />

                        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.

            84
<pb n="92" />

                   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

                                                                                          85
<pb n="93" />

                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

           86
<pb n="94" />

                       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.

                                                                                           87
<pb n="95" />

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

                                                 COMMUNITY PROGRAMS

                                                                                      89
<pb n="96" />

                       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

           90
<pb n="97" />

               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-
<pb n="98" />

                (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.

          92
<pb n="99" />

                                    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.
<pb n="100" />

                                 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.

           94
<pb n="101" />

             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.

                                                                                        95
<pb n="102" />

                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.

          96
<pb n="103" />

                            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,

                                                                                           97
<pb n="104" />

                 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

          98
<pb n="105" />

              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.

                                                                                            99
<pb n="106" />

                     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
<pb n="107" />

                           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
<pb n="108" />

                                                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 &amp;
                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
<pb n="109" />

                         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
<pb n="110" />

                                      FIELD ADVISOR'S CHECKLIST

            COMMUNITY:       &lt;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 &amp; NFIP requir   Jents:

           104
<pb n="111" />

           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
<pb n="112" />

                                  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
<pb n="113" />

               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
<pb n="114" />

                 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
<pb n="115" />

                     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
<pb n="116" />

                                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
<pb n="117" />

                   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.,
<pb n="118" />

                             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
<pb n="119" />

                                       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
<pb n="120" />

                                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
<pb n="121" />

                              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)
<pb n="122" />

                                     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
<pb n="123" />

              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
<pb n="124" />

                          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&amp; 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
<pb n="125" />

              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
<pb n="126" />

                                      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
<pb n="127" />

                                  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

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

        Findings from Call:
             sr*4                                                            "

                                                                   ew-

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

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

                                                                                121
                                                              CCO
<pb n="128" />

                                      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
<pb n="129" />

              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
<pb n="130" />

                            PART V: RECOMMENDATIONS

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

                                                                         125
<pb n="131" />

                                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
<pb n="132" />

             (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
<pb n="133" />

           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
<pb n="134" />

                 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
<pb n="135" />

               (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
<pb n="136" />

                  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
<pb n="137" />

                    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
<pb n="138" />

                  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
<pb n="139" />

                                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.

                      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.
<pb n="140" />

                                                               @j I jffi@ I V@j
                                                                                         IR
                                                                 3 6668 00000 6355
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