Flood Map Modernization: Program Strategy Shows Promise, but
Challenges Remain (31-MAR-04, GAO-04-417).
Flood maps identify areas at greatest risk of flooding and
provide the foundation for the National Flood Insurance Program
(NFIP) managed by the Federal Emergency Management Agency (FEMA).
The maps are used by (1) communities to establish minimum
building standards designed to reduce the impact of flooding, (2)
FEMA to set insurance rates, and (3) lenders to identify property
owners who are required to purchase flood insurance. Nearly 70
percent of all flood maps are more than 10 years old, according
to FEMA. In an effort to update its flood maps, FEMA is
implementing a $1 billion, 5-year map modernization program. GAO
was asked to review the progress of FEMA's map modernization
program.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-04-417
ACCNO: A09659
TITLE: Flood Map Modernization: Program Strategy Shows Promise,
but Challenges Remain
DATE: 03/31/2004
SUBJECT: Emergency preparedness
Flood control
Flood control management
Flood insurance
Strategic planning
Insurance premiums
Standards and standardization
Data collection
Intergovernmental relations
Maps
FEMA National Flood Insurance Program
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GAO-04-417
United States General Accounting Office
GAO Report to the Chairman, Subcommittee on Housing and Community Opportunity,
Committee on Financial Services, House of Representatives
March 2004
FLOOD MAP MODERNIZATION
Program Strategy Shows Promise, but Challenges Remain
GAO-04-417
March 2004
FLOOD MAP MODERNIZATION
Program Strategy Shows Promise, but
Highlights of GAO-04-417, a report to the Challenges RemainChairman,
Subcommittee on Housing and
Community Opportunity, Committee on Financial Services, House of
Representatives
Flood maps identify areas at Through its map modernization program, FEMA
intends to use advanced
greatest risk of flooding and technologies to produce more accurate and
accessible digital flood maps
provide the foundation for the available on the Internet. These maps are
expected to improve community
National Flood Insurance Program efforts to reduce the impact of floods,
increase property owners' use of flood
(NFIP) managed by the Federal
Emergency Management Agency insurance, and improve community, state and
federal efforts to reduce the
(FEMA). The maps are used by risks of other natural and man-made hazards.
(1) communities to establish
minimum building standards In developing digital flood maps, FEMA plans to
incorporate data that are of
designed to reduce the impact of a level of specificity and accuracy
commensurate with communities' relative
flooding, (2) FEMA to set insurance flood risk. According to FEMA, there
is a direct relationship between the
rates, and (3) lenders to identify types, quantity, and detail of the data
and analysis used to develop maps and
property owners who are required the costs of obtaining and analyzing
those data. Although FEMA ranked the
to purchase flood insurance. Nearly nation's 3,146 counties from highest
to lowest risk, it has not yet established
70 percent of all flood maps are data standards that describe the
appropriate level of detail, accuracy, and
more than 10 years old, according analysis required to develop digital
maps based on risk level. Without such
to FEMA. In an effort to update its
flood maps, FEMA is implementing standards, FEMA cannot ensure that it
uses the same level of data collection
a $1 billion, 5-year map and analysis for all communities in the same risk
category. Such standards
modernization program. GAO was can also help FEMA to target its map
modernization resources more
asked to review the progress of efficiently by matching the level of data
collection and analysis with the level
FEMA's map modernization of flood risk.
program. FEMA has developed partnerships with states and local entities
that have
begun mapping activities and has a strategy on how to best work with these
To help ensure that FEMA's map entities. However, the overall
effectiveness of FEMA's future partnering modernization program achieves
efforts is uncertain because FEMA has not yet developed a clear strategy
for its intended benefits, GAO is partnering with communities with less
resources and little or no experience making several recommendations. in
flood mapping. By developing such a strategy, FEMA will be better able to
FEMA should address differences identify and use the most effective
approaches to engage all of its partners in among the communities for
which map modernization. flood maps are being developed- Comparison of Old
Paper and New Digital Map Sections in North Carolina whether those
differences arise
from different levels of flood risk
or different levels of capacity and
resources to assist with flood
mapping.
www.gao.gov/cgi-bin/getrpt?GAO-04-417.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact William O. Jenkins,
202-512-8777, [email protected].
Source: North Carolina Department of Emergency Management.
Contents
Letter
Results in Brief Background Map Modernization Intends to Use Advanced
Technologies to
Produce More Accurate and Accessible Digital Flood Maps FEMA Expects Map
Modernization to Increase the Likelihood Maps Will Be Used for Risk
Management FEMA's Strategy for Map Modernization Shows Promise, but
Challenges Remain Conclusions Recommendations Agency Comments
1
3 5
9
16
29 40 41 42
Appendix I Objectives, Scope, and Methodology
Appendix II Users of Flood Maps
Appendix III GAO Contacts and Staff Acknowledgments 49
GAO Contacts 49 Staff Acknowledgments 49
Table
Table 1: FEMA's Objectives for Map Modernization and Our Observations on
the Objectives and Challenges
Figures
Figure 1: Age of the Nation's Current Flood Map Inventory 9 Figure 2: Key
GIS Layers or Themes for Digital Flood Maps 11 Figure 3: Comparison of
Original and Updated Floodplain for Plum
Creek in Douglas County, Colorado 13 Figure 4: Use of LIDAR Technology 15
Figure 5: Comparison of Old Paper and New Digital Map Sections
in North Carolina 16 Figure 6: Expected Benefits of Map Modernization 18
Figure 7: Comparison of FEMA and Sarasota County Floodplain after
Remapping 20
Figure 8: Impact of Capital Improvement Project on Floodplain in Sarasota
County 22
Figure 9: Expanded Floodplain Boundary for Regulating New Construction in
Mecklenburg County, North Carolina 23
Figure 10: Flooding in Greenville, North Carolina, during Hurricane Floyd
27
Figure 11: Example of Spill Response Model in Harris County, Texas 28
Figure 12: Comparison of Cumulative FEMA Funding for Mapping Data with the
Total Cumulative Dollar Value of Mapping Data Produced through CTP Program
36
Figure 13: Status of Remapping in North Carolina 38
Abbreviations
CTP Cooperating Technical Partner DHS Department of Homeland
Security FEMA Federal Emergency Management Agency GIS Geographic
Information Systems LIDAR Light Detection and Ranging NFIP National
Flood Insurance Program
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
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separately.
United States General Accounting Office Washington, DC 20548
March 31, 2004
The Honorable Robert W. Ney Chairman Subcommittee on Housing and
Community Opportunity Committee on Financial Services House of
Representatives
Dear Mr. Chairman:
Floods inflict more damage and economic losses upon the United States than
any other natural disaster. During the 10 years from fiscal year 1992
through fiscal year 2001, flooding caused over 900 deaths and resulted in
approximately $55 billion in damages.1 Since its inception 36 years ago,
the National Flood Insurance Program (NFIP) has combined the
development of flood maps to identify the areas at greatest risk of
flooding with mitigation2 efforts to reduce or eliminate flood risks to
people and property and the availability of insurance that property
owners can purchase to protect themselves from flood losses. To date, the
flood insurance program has paid about $12 billion in insurance claims,
primarily from policyholder premiums, that otherwise would have been
paid, at least in part, from taxpayer-funded disaster relief.
The Federal Emergency Management Agency (FEMA) is responsible for
managing the NFIP, including the development of flood maps.3 Accurate
flood maps that identify the areas at greatest risk of flooding are the
foundation of the NFIP. The maps are principally used by (1) the
1Data are from the U.S. Army Corps of Engineers in cooperation with the
National Weather Service.
2Mitigation is defined by the Federal Emergency Management Agency as
sustained action that reduces or eliminates long-term risk to people and
property from hazards and their effects.
3Prior to March 2003, FEMA was an independent agency whose Federal
Insurance and Mitigation Administration was responsible for managing the
flood insurance program. The Homeland Security Act of 2002, P.L. 107-296
(Nov. 25, 2002), transferred FEMA and all its responsibilities to the
Emergency Preparedness and Response Directorate within the new Department
of Homeland Security. This transfer was effective March 1, 2003.
Currently, the Mitigation Division within FEMA is responsible for the
flood insurance program, including flood map modernization.
approximately 20,000 communities participating in the NFIP to adopt and
enforce the program's minimum building standards for new construction
within the maps' identified floodplains, (2) FEMA to develop accurate
flood insurance policy rates based on flood risk, and (3) federally
regulated mortgage lenders to identify those property owners who are
statutorily required to purchase federal flood insurance. Under the
National Flood Insurance Act of 1968, as amended,4 property owners whose
properties are within the designated floodplain and have a mortgage from a
federally regulated financial institution are required to purchase federal
flood insurance. Flood maps can become outdated for a variety of reasons,
such as erosion or community growth and development that can affect the
drainage patterns of rainwater. Thus, flood maps must be periodically
updated to assess and map changes in the boundaries of floodplains that
result from community growth, development, erosion, and other factors that
affect the boundaries of areas at risk for flooding. According to FEMA,
limited funding for flood mapping has resulted in a backlog of outdated
maps. FEMA estimates that as of March 2004 nearly 70 percent of the
nation's flood maps were more than 10 years old and reflected outdated
data that could affect the ability to accurately identify current flood
hazard areas.
With congressional support and funding, FEMA has embarked on a $1 billion,
5-year effort to update the nation's flood maps. Recognizing that FEMA is
currently in the early stages of its map modernization effort, our
objectives for this review were to answer the following questions: (1) How
is map modernization intended to improve the accuracy and accessibility of
the nation's flood maps? (2) What are the expected benefits of more
accurate and accessible flood maps? (3) To what extent does FEMA's
strategy for managing the map modernization program support the
achievement of these benefits and what, if any, limitations could affect
the implementation of the strategy?
To answer these questions, we analyzed available information from FEMA on
the program's purpose, objectives, and status and met with agency
officials in headquarters and in the regional offices to discuss the
program's progress. We also conducted site visits to states and
communities that have already begun to modernize their flood maps and
interviewed industry organizations such as the Association of State Flood
Plain Managers, the National Association of Flood and Stormwater
4See 42 U.S.C. 4001 et seq.
Results in Brief
Management Agencies, and the National Emergency Management Association. We
conducted our work from April 2003 to March 2004 in accordance with
generally accepted government auditing standards. See appendix I for more
details on our scope and methodology.
Through map modernization, FEMA intends to produce more accurate and
accessible flood maps by using advanced technology to gather accurate data
and make the flood maps, and the digital information on which they are
based, available on the Internet. For example, displaying map data in
digital Geographic Information Systems format permits consistent, accurate
display and ready electronic retrieval of a variety of map features,
including elevation data and the location of key infrastructure, such as
utilities. According to FEMA, nearly 70 percent of the nation's
approximately 92,222 flood maps are more than 10 years old, and many of
these maps no longer reflect current flood hazard risks because of such
changes as erosion and development that can alter drainage patterns and
thus the areas at highest risk of flooding. Moreover, since many flood
maps were created or last updated, there have been improvements in the
techniques for assessing and displaying flood risks.
FEMA expects that by producing more accurate and accessible digital flood
maps through map modernization, the nation will benefit in three ways.
First, communities can use more accurate digital maps to reduce flood risk
within floodplains by more effectively regulating development through
zoning and building standards. Second, accurate digital maps available on
the Internet will facilitate the identification of property owners who are
statutorily required to obtain or who would be best served by obtaining
flood insurance. Third, accurate and precise data will help national,
state, and local officials to accurately locate infrastructure and
transportation systems (e.g., power plants, sewage treatment plants,
railroads, bridges, and ports) to help mitigate and manage risk for
multiple hazards, both natural and man-made.
FEMA's strategy for managing map modernization is designed to support the
expected program benefits, but FEMA's approach to implementing the
strategy raises several concerns that could hamper the agency's efforts.
FEMA's implementation approach is based on four objectives: (1) establish
and maintain a premier data system, (2) expand outreach and better inform
the user community, (3) establish and maintain effective partnerships, and
(4) achieve effective program management.
o Establish and maintain a premier data system: Although FEMA's efforts
to establish a new data system could result in more accurate
flood maps and make it easier to access and use the revised flood maps,
FEMA has not yet established clear standards for the types, quantity, and
specificity of data collection and analysis associated with different
levels of flood risk. FEMA has ranked the nation's 3,146 counties from
highest to lowest flood risk. According to FEMA, communities at the
highest risk of flooding require the most extensive, detailed data and
analysis, but the same level of data collection and analysis may not be
necessary to create accurate, useful maps for communities with lower flood
risks. Defining the level of data collection and analysis for different
levels of risk is important because obtaining and analyzing flood map data
is time-consuming and expensive, and the more detailed and specific the
data, generally the greater the effort and costs required to obtain it. By
identifying the types, quantity, and specificity of the data and analysis
needed for communities based on their risk, FEMA can better ensure that
data collection and analysis is consistent for all communities with
similar risk and that it is using its resources efficiently while
producing maps that are accurate and useful for communities at different
levels of flood risk. FEMA acknowledges the need to develop such
standards, but has not yet developed draft standards or included this task
into its map modernization implementation plan.
o Expand outreach and better inform the user community: FEMA's planned
expanded outreach efforts are intended to increase public awareness and
obtain community acceptance of the updated flood maps because the updated
information could potentially identify changes in floodplain boundaries
and, therefore, affect property owners, including whether or not their
property's location may require them to purchase federal flood insurance.
FEMA's intended outcome for these outreach efforts is to reduce community
vulnerability to natural and man-made hazards and increase participation
in the flood insurance program. Because FEMA does not have the authority
to require that affected property owners take steps to mitigate their
properties against flood risks or to ensure that owners whose properties
are in the floodplain purchase flood insurance, effective outreach is
essential to ultimately achieve these benefits.
o Establish and maintain effective partnerships: FEMA's objective for
building and maintaining mutually beneficial partnerships is designed to
facilitate and support the efficient production and effective use of maps.
FEMA recognizes that local, state, and federal agencies, that have been
working on mapping activities for years, have the resources and potential
to positively affect the quality and quantity of the data collected and
improve the way these data are used. In
addition, these partnerships can enable FEMA to leverage its resources and
reduce the federal costs of map modernization. FEMA has developed a
strategy for partnering with these agencies to encourage greater
involvement in map modernization, including the contribution of resources.
However, the overall effectiveness of the agency's future partnering
efforts is uncertain because FEMA has not yet developed a clear strategy
for partnering with communities that have few resources, limited mapping
capability, and little history of flood mapping activities.
o Achieve effective program management: In March 2004, FEMA awarded a
performance-based contract to a single contractor to oversee map
modernization that includes performance measures to gauge the success of
its efforts. Through a staffing analysis, FEMA has determined that it
needs 75 staff with specific, identified skills to effectively monitor and
manage the contract and overall map modernization program. As of March
2004, FEMA had hired 1 of the 75 staff, had developed plans to hire or
transfer 43 others, but had not yet determine how it would acquire the
remaining 31 positions. FEMA has not clearly defined performance measures
related to whether (1) the revised maps meet any established standards for
accuracy and (2) outreach efforts have been successful in increasing the
community and individual awareness and use of flood maps.
To help ensure that FEMA's map modernization program achieves its intended
benefits, we make recommendations to the Secretary of Homeland Security to
direct the Undersecretary of Emergency Preparedness and Response to
address data and analysis standards, partnering with state and local
governments, and program management. We provided a copy of our draft
report to the Department of Homeland Security (DHS) for comment. In its
oral comments, DHS generally concurred with the report's findings and
recommendations and provided technical comments that we incorporated where
appropriate.
Background FEMA is the primary federal agency responsible for assisting
state and local governments, private entities, and individuals to prepare
for, mitigate, respond to, and recover from natural disasters, including
floods. FEMA's NFIP has served as a key component of the agency's efforts
to minimize or mitigate the damage and financial impact of floods on the
public, as well as to limit federal expenditures needed after floods
occur.
In 1968, to address the increasing amount of flood damage, the lack of
readily available insurance for property owners, and the cost to the
taxpayer for flood-related disaster relief, the National Flood Insurance
Act of 1968,5 created the NFIP. Since its inception, the program has
sought to minimize flood-related property losses by making flood insurance
available on reasonable terms and encouraging its purchase by people who
need flood insurance protection-particularly those living in the areas at
highest risk of flooding known as special flood hazard areas. The program
identifies and maps flood-prone areas in the country, makes flood
insurance available to property owners in the nearly 20,000 communities
that currently participate in the program,6 and requires floodplain
management efforts to mitigate flood hazards on the part of participating
communities.
FEMA's flood maps are one of the basic, essential tools for flood hazard
mitigation in the United States. FEMA estimates that the maps are used an
estimated 30 million times annually in the private and public sectors.
FEMA uses the maps to identify the floodplain boundaries in which flood
insurance is required and to set flood insurance rates. Mortgage lending
institutions use the maps to determine who is required to purchase flood
insurance and ensure that flood insurance is purchased and maintained for
these properties. Community planning officials, land developers, and
engineers use the maps for designing new buildings and infrastructure to
be safe from flooding. See appendix II for more information on the various
stakeholders that use and rely upon flood maps.
Flood maps provide the basis for establishing floodplain building
standards that participating communities must adopt and enforce as part of
the program. For a community to participate in the program, any structures
built within special flood hazard areas-also known as 100-year
floodplains7-that have a 1 percent or greater chance of experiencing
flooding in any given year must be built according to the program's
building standards whose purpose is to minimize flood losses. A key
component of the program's building standards that must be followed by
participating communities is a requirement that the lowest floor of the
5P.L. 90-448, (Aug. 1, 1968).
6Also included are Puerto Rico and the Virgin Islands.
7For clarity and ease of discussion throughout the report, we use the term
"floodplain" in all discussions where we address the special flood hazard
area or 100-year floodplain.
structure be elevated to or above the base flood level-the elevation at
which there is a 1 percent chance of flooding in a given year. The
administration has estimated that local governments' compliance with the
program's standards for new construction is saving over $1 billion
annually in flood damage avoided.
Flood maps also provide the basis for setting insurance rates and
identifying properties whose owners are required to purchase flood
insurance. When the NFIP was created, the purchase of flood insurance was
voluntary. To increase the impact of the program, however, Congress
amended the original law in 1973 to require the purchase of flood
insurance in certain circumstances. Flood insurance is required for
structures in special flood hazard areas of communities participating in
the program if (1) any federal loans or grants were used to acquire or
build the structures or (2) the structures have outstanding mortgage loans
made by lending institutions that are regulated by the federal government.
Owners of properties without mortgages or properties with mortgages held
by unregulated lenders were not, and still are not, required to purchase
flood insurance, even if the properties are in special flood hazard areas.
Federal regulations require that FEMA communicate potential changes in
flood risk to the public when it decides to initiate a flood mapping study
and when it is ready to release preliminary maps. At the beginning of the
mapping process, FEMA is required to notify community stakeholders.8 When
FEMA is ready to release preliminary maps, the agency must publish the
proposed base flood elevations in the Federal Register for public comment
and notify the community of the results of the study.9 When the final map
is approved and implemented, FEMA publishes another Federal Register
notice.10
8FEMA is required to contact community stakeholders, such as the state
coordinating agency and other appropriate community officials, to discuss
the scope and methodology for the proposed flood map study. 44 C.F.R. sec.
66.5.
9FEMA is required to publish the proposed flood elevations in a prominent
local newspaper at least twice during the 10-day period following the
notification of the community chief executive officer. Property owners
have 90 days from the second newspaper publication to appeal the proposed
flood elevations. 44 C.F.R. secs. 67.4, 67.5.
10Final flood elevations must be published in the Federal Register and
copies sent to the community chief executive officer, all individual
appellants, and the state-coordinating agency. 44 C.F.R. 67.11.
In the early 1990s, some of the data and information FEMA collected to
develop flood maps were becoming available in digital format. In 1994, the
President issued Executive Order 12906, which mandated that standards for
digital geographic data be applied uniformly across the federal
government. Anticipating that electronic data would soon become the
standard vehicle for information delivery and in an attempt to make flood
map production more cost-effective and efficient, FEMA developed a
prototype for a digital flood map.
In 1997, FEMA developed its initial flood map modernization plan that
outlined the steps necessary to update the nation's flood maps to digital
format and streamline FEMA's operations in raising public awareness of the
importance of the maps and responding to requests to revise them. This
initial plan and subsequent updates to the plan reflected the
recommendations of the Technical Mapping Advisory Council created by
Congress and active from 1995-2000. The council provided a number of
recommendations which were aimed at making the digital flood map the
future method for assessing flood hazard risk and setting federal
insurance rates. Recognizing the importance of updating the nation's flood
maps, Congress appropriated additional funds in fiscal years 2000-2002.
FEMA used these funds to launch its map modernization program through such
activities as developing new flood mapping standards and procedures,
expanding the Cooperating Technical Partner (CTP) program that recognizes
and encourages state and local participation in flood hazard data
development and maintenance and developing some digital flood maps. In
fiscal year 2003, Congress appropriated $150 million, allowing FEMA to
initiate a full-scale update of the nation's flood maps called the
Multi-Hazard Flood Map Modernization Program,11 an effort FEMA expects to
take about 5 years and cost about $1 billion. In fiscal year 2004,
Congress appropriated an additional $200 million for map modernization,
and the administration has requested an additional $200 million for fiscal
year 2005 to continue the program. FEMA has established four primary
objectives for implementing map modernization: (1) establish and maintain
a premier data collection and delivery system, (2) expand outreach and
better inform the user community, (3) build and maintain mutually
beneficial partnerships, and (4) achieve effective program management. In
March 2004, FEMA awarded a performance-based
11For clarity and ease of discussion throughout the report, we use the
term "map modernization" in all discussions where we address the
Multi-Hazard Flood Map Modernization Program.
Map Modernization Intends to Use Advanced Technologies to Produce More
Accurate and Accessible Digital Flood Maps
contract for overseeing map modernization that includes contractor
performance measures for each of these objectives.
Through map modernization, FEMA intends to produce more accurate and
accessible flood maps by using advanced technology to gather accurate data
and make the resulting information available on the Internet. Currently,
many of the flood maps in FEMA's inventory do not accurately reflect the
true flood hazard risks because over time, new development and other
factors altered watersheds and floodplains faster than the maps could be
updated. For the most part, the $35 million to $50 million in annual flood
insurance policy fees has been the only source of funding for updating
flood maps, and according to FEMA, the agency has not been able to keep
the maps updated with the funds available. As a result, nearly 70 percent
of the nation's approximately 92,222 flood maps12 are more than 10 years
old and many of these maps reflect inaccurate data, according to FEMA.
Figure 1 shows the age distribution of the current map inventory.
Figure 1: Age of the Nation's Current Flood Map Inventory
<5 years old
5-10 years old
10-15 years old
>15 years old
Source: FEMA.
Over time, physical conditions in watersheds and floodplains can change,
and improvements in the techniques for assessing and displaying flood
12The 92,222 flood maps represent nearly 20,000 communities.
risks are made. FEMA plans to use the latest technology, such as
Geographic Information Systems (GIS), to create accurate digital flood
maps. GIS technology provides the foundation for achieving FEMA's goals of
melding different types and sources of data to create the new digital
flood maps and making the new digital flood maps available to a variety of
users over the Internet.
The primary function of GIS is to link multiple digital databases and
graphically display that information as maps with potentially many
different types of "layers" of information. When layers of information are
formatted using the same standards, users can potentially overlay various
layers of information about any number of specific topics to examine how
the layers interrelate. Each layer of a GIS map represents a particular
"theme" or feature, and one layer could be derived from a data source
completely different from the other layers. For example, one theme could
represent all the streets in a specified area. Another theme could
correspond to the topography or elevation data of an area, and others
could show aerial photography and streams in the same area. These themes
are all key elements needed to create flood maps that accurately depict
floodplains and can be used to identify properties in these areas. In
preparing for full-scale implementation of map modernization, FEMA has
established standards and graphic specifications for digital flood maps
created with GIS. Figure 2 shows the concept of data themes in GIS for
flood maps.
Figure 2: Key GIS Layers or Themes for Digital Flood Maps
Source: FEMA.
GIS technology also enables the creation of more accurate and accessible
maps than would be possible with older mapping methods and technology. The
majority of FEMA's flood map inventory was produced using manual
techniques that have inherent accuracy and accessibility limitations. For
example, in creating traditional paper flood maps, field measurements
taken by surveyors would have been transferred by hand to paper base maps.
If the paper base map contained any inaccuracies, then the fieldsurvey
data could be shown in the wrong place on the final flood map. This would
then result in floodplain boundaries being shown in the wrong place.
Douglas County, Colorado
Recent remapping efforts in Douglas County, Colorado, show the accuracy of
digital maps using GIS technology compared with paper maps created using
manual techniques. As seen in figure 3, some areas (around cross section
J) shown outside the floodplain on the original map will be shown in the
floodplain based on the updated flood hazard information from a new
mapping study using GIS technology. More critically, some areas shown
outside the floodplain on the original map will now be shown in the
floodway, the most dangerous area of the floodplain (greatest depth,
highest flood water velocity). According to FEMA and community officials,
the limitations of the manual techniques used to create the original map
contributed to the resulting inaccuracy.
Figure 3: Comparison of Original and Updated Floodplain for Plum Creek in
Douglas County, Colorado
Source: FEMA and Denver Urban Drainage and Flood Control District.
Using GIS technology to create digital flood maps minimizes mapping errors
and improves accuracy because each data component (e.g., streams, streets,
etc.) would have a common geographic reference system.
By their nature, paper flood maps have limited accessibility as compared
with a digital map that can be made available on the Internet. The
expansion of Internet connectivity in recent years has substantially
enhanced the potential value of digital maps created with GIS because now
it is possible to locate and connect data from many distinct GIS databases
to develop analytical information on almost any topic that is associated
with physical locations. Digital flood maps created according to FEMA's
standards are intended to provide users not only with the ability to
determine the flood zone and base flood elevations for a particular
location, but also with the ability to access other information like road,
stream, and public land survey data. Communities could use this
information for a variety of purposes, including decisions on future
development and evacuation routes.
As part of map modernization, FEMA has promoted the use of a variety of
advanced technologies to improve the accuracy of flood maps. In recent
years, for example, where it deems it appropriate, FEMA has promoted the
use of Light Detection and Ranging (LIDAR) remote sensing technologies to
generate highly detailed, digital elevation data. Elevation data are a key
component needed to determine flood risk and identify floodplain
boundaries. According to FEMA, for very flat areas where small changes in
elevation can have a large impact on where flood plain boundaries are
drawn, LIDAR can provide the level of detail needed to accurately
delineate these boundaries. Communities can also use detailed, digital
elevation data for planning and land development purposes. Figure 4 shows
an airplane equipped with laser-pulsing sensors using LIDAR to gather
digital elevation data to measure the contours and crevices that determine
where floodwaters collect.
Figure 5: Comparison of Old Paper and New Digital Map Sections in North
Carolina
Source: North Carolina Floodplain Mapping Program.
FEMA Expects Map FEMA expects map modernization to increase the likelihood
that the more
accurate and accessible maps will be used for risk management purposes.
Modernization to Specifically, FEMA expects the new maps to be used to (1)
improve flood Increase the mitigation, (2) increase flood insurance
participation, and (3) improve
"multi-hazard" mitigation and risk management capabilities. First, FEMA
Likelihood Maps Will expects communities to be able to use these new and
revised maps to Be Used for Risk better manage and mitigate flood risk by
regulating floodplain
development through building codes, ordinances, and regulations. Second,
Management the new maps also have the potential to help increase flood
insurance participation because they will more accurately identify those
properties that are in the floodplain and whose owners would be required
to purchase flood insurance. Compared with the existing paper maps,
accessing the new maps through the Internet will make it much easier for
lenders to identify property owners who should have flood insurance. In
addition, the newly revised flood maps should more accurately identify all
properties in the floodplain, including those whose owners do not have a
mortgage or whose mortgage is held by a lender that is not federally
regulated. Accurately identifying these property owners should assist FEMA
and communities in targeting their outreach about the importance of flood
insurance. Third, the data and infrastructure developed by map
modernization is also expected to help national, state, and local
officials mitigate and manage risk from multiple hazards, both natural and
manmade. Accurate digital maps can provide more precise data on such
things as the location of hazardous material facilities, power plants,
railroads, and airports to state and national officials for planning
development as well as to assess internal weaknesses and evacuation
routes. (Fig. 6 highlights these expected benefits.)
Figure 6: Expected Benefits of Map Modernization Map Modernization
Source: GAO.
Map Modernization Is Expected to Improve Flood Mitigation
The more accurate and updated flood hazard information produced through
map modernization is expected to help improve flood mitigation in
participating communities. The NFIP requires participating communities to
adopt and enforce building standards based on the floodplain boundaries
and base flood elevations when maps are updated. For example, the lowest
floor of structures in new construction must be elevated to at least the
base flood elevations identified on the maps. FEMA's policy is to monitor
communities to ensure that they have adopted building standards that meet
the minimum NFIP criteria and to ensure that they are effectively
enforcing these standards. If communities fail to establish and enforce
minimum NFIP flood plain building standards, FEMA can suspend availability
of federal flood insurance.
Communities also may use updated flood hazard data to take actions to
mitigate flooding that go beyond adopting the building standards required
by the NFIP. For example, communities may use the data from the maps to
identify where to conduct capital improvement projects designed to
Sarasota County's Use of Flood Map Data for Storm Water Capital
Improvement Projects
mitigate flooding of structures in the floodplain. In addition, FEMA has
established a Community Rating System that provides discounts on flood
insurance premiums for those communities that take mitigation actions
beyond those required by the NFIP.
Sarasota County, Florida, is in the process of modernizing its flood maps
and has been using the maps and the models behind them to implement
stormwater capital improvement projects whose purpose is to mitigate the
flood risk for structures now located in the floodplain. These efforts
have also resulted in lower insurance premiums for property owners.
In the late 1990s, because Sarasota County officials believed that current
maps did not accurately reflect changes to the floodplain that had
occurred due to development and other factors, they began an effort to
aggressively remap the county's watersheds using GIS and new flood
modeling technologies. At the time, the county had experienced several
significant flooding events where hundreds of properties not depicted in
the floodplain on its 11-year old maps were damaged. Figure 7 shows both
the increase and decrease in the floodplain based on the county's
remapping efforts.
Figure 7: Comparison of FEMA and Sarasota County Floodplain after
Remapping
Source: Sarasota County Center for Watershed Management.
The county has been using the maps to implement storm water improvement
projects such as retention ponds and levees that are designed to improve
drainage and, therefore, alter the floodplain. Ultimately, these projects
would result in structures no longer being in the floodplain. County
officials estimate that they have reduced the number of structures in the
floodplain by 75 percent (from 800 to under 200) through
these projects. According to these officials, the reduction in their
Community Rating System rating from an 8 to a 6 was due in large part to
their remapping efforts. They estimate that this reduction is saving the
community over $1 million a year in flood insurance premiums. Figure 8
shows an example of the impact one such capital improvement project had on
the floodplain in Sarasota County.
Figure 8: Impact of Capital Improvement Project on Floodplain in Sarasota County
Mecklenburg County, Mecklenburg County, North Carolina, provides another
example of how
North Carolina communities may use revised maps as a basis for adopting
and enforcing building standards that exceed the standards required by the
NFIP.
In February 2004, Mecklenburg County, North Carolina, issued final digital
maps that not only show the floodplain boundaries and base flood
elevations used by FEMA to set insurance rates, but also include local
land use maps designed to guide future development. (See fig. 9.) These
maps are more restrictive than the FEMA maps, which are used for setting
insurance rates. The county uses these maps to require that the lowest
floor of all new construction is built an additional foot above the future
minimum base flood elevation identified by the map. Engineering and
economic studies estimate that this higher standard will save over $300
million in structure and content losses due to future flooding. As in the
case of Sarasota County, adopting these higher standards should result in
a better Community Rating System rating for the county and reduce
insurance rates for property owners.
Figure 9: Expanded Floodplain Boundary for Regulating New Construction in
Mecklenburg County, North Carolina
Source: Charlotte-Mecklenburg Storm Water Services.
Map Modernization Is Map modernization has the potential to help increase
flood insurance Expected to Help Increase participation. The accuracy of
the new maps should better identify at-risk Flood Insurance property
owners who would be best served by obtaining flood insurance
whether or not the owners would be required to purchase insurance
underParticipation the NFIP's mandatory purchase requirement. Moreover,
the digital, GISbased maps should make flood risk information more
accessible to a
Outreach Efforts in Wilson and Johnston Counties, North Carolina
variety of users such as lenders and community officials who could conduct
targeted outreach at these property owners.
Recent outreach activities conducted during remapping in Wilson and
Johnston counties in North Carolina provide an example of the types of
information that can be provided to communities and property owners
through outreach efforts during map modernization.
As part of its map modernization program, the state of North Carolina
holds two meetings. The first meeting is held with the county and
community officials and floodplain administrators, and the second meeting
is open to the general public. The purpose of the meetings is to provide
an overview of the state's program; an outline of flood hazard data
changes between the current maps and preliminary revised maps; and
guidance on the use of the maps, including how to view and download data
from the state's Web site. After the state had completed preliminary
studies and maps for Wilson and Johnston counties, community officials
used the digital, GIS-based maps to identify structures that are located
in the newly identified floodplain. The counties then sent out letters to
these property owners that
o notified them that their property was in a floodplain,
o provided a telephone number to call for more information,
o announced upcoming public meetings where the preliminary maps would be
discussed, and
o identified the state's Internet site where the flood maps could be
viewed (Wilson County).
By providing this information in advance, property owners could know
before the meeting whether their property was in the newly designated
floodplain. According to community officials, their outreach activities
provided the information necessary for the public to become aware of their
risk and know what actions could be taken to mitigate these risks.
It is important to note, however, that FEMA, states, and communities do
not have the authority to ensure that property owners who are subject to
the mandatory purchase of flood insurance requirement actually purchase
flood insurance. It is the federally regulated lenders' responsibility to
ensure that borrowers purchase flood insurance and that the insurance
policy is maintained throughout the loan's life as each new lender
servicing the loan becomes aware that the affected property is at risk for
flooding. Furthermore, owners of properties without mortgages or
properties with mortgages held by unregulated lenders are not required to
purchase flood insurance, even if the properties are in floodplains.
Map Modernization Is Expected to Improve Multi-Hazard Mitigation and Risk
Management Capabilities
Flood-Inundation Application Developed by North Carolina
FEMA expects that the data developed, collected, and distributed through
map modernization will help national, state, and local emergency managers
mitigate and manage risk posed by other natural and man-made hazards.
Accurate digital base maps provide more precise data to state and national
officials for planning, such as the location of hazardous material
facilities, power plants, utility distribution facilities, and other
infrastructure (bridges, sewage treatment plants, buildings, and
structures). According to FEMA, map modernization will also support DHS's
overall goal to reduce the nation's vulnerability to terrorism by
providing GIS data and capabilities to other departmental functions. For
example, more accurate information on transportation systems such as
railroads, airports, harbors, ports, and waterways should be helpful in
assessing internal weaknesses and evacuation routes.
North Carolina's use of information collected during flood mapping to
develop a flood-inundation application exemplifies how the data collected
through map modernization can be used for other risk management purposes.
Leveraging the work done through the floodplain mapping program, North
Carolina is in the process of establishing a real-time flood-inundation
and flood forecast mapping Web application that will provide the public
with valuable safety information during weather events. During a storm,
the application will provide maps and information over the Internet that
display which land area, roads, and bridges are inundated by floodwaters.
Furthermore, to help ensure that the public is aware of high flood risk
areas, the state plans to develop an automated alert network that will
utilize different media to notify and warn emergency managers, law
enforcement, and the general public. North Carolina is currently working
with television broadcasters in the region to broadcast warnings and
upto-date safety information based upon information provided through the
Web application. The majority of deaths during Hurricane Floyd, which hit
North Carolina in 1999, occurred to individuals driving over
floodinundated roads and bridges. North Carolina hopes that their
real-time and forecasted inundation mapping application will help to
prevent such deaths during future storm events.
The flood forecasting component of North Carolina's flood-inundation and
forecasting application was recently tested during Hurricane Isabel, which
struck in September of 2003. Using data collected by North Carolina, the
National Weather Service released an experimental Peak Forecast Inundation
Web site for predicting the flooding effects of the hurricane. This was a
new level of capability for the National Weather Service by forecasting
flood-inundation throughout a major portion of the river basin rather than
focusing solely on fixed forecasting locations. The implementation of this
new flood forecasting technology will greatly enhance North Carolina's
flood warning Web application.
Figure 10 shows an example of how the flood-inundation application is
intended to work. As floodwaters rise and spread out over the landscape,
the flood-inundation application will produce maps to show the extent of
flooding and when roads, critical facilities, and other structures will
become flooded. The following maps show flooding in Greenville, North
Carolina, and are based on flood levels caused by Hurricane Floyd.
Harris County, Texas, offers another example of how the digital data
developed through map modernization could be used to plan for and respond
to man-made disasters.
To demonstrate the multi-hazard use of the digital data, community
officials showed how a spill response model could be developed to
determine the path of a petroleum spill at a Houston area refinery. The
model, developed with digital data by a private consultant, uses both
elevation data and aerial imagery collected through map modernization to
provide officials and emergency response personnel critical information to
determine the path of a chemical spill and potentially impacted waterways.
This information should provide local officials with valuable
Source: North Carolina Floodplain Mapping Program.
Harris County, Houston, Texas
information to aid in their mitigation and evacuation efforts and to
protect natural habitats. The figure shows how petroleum at a Houston area
refinery would probably flow from specific tanks if ruptured.
Source: Harris County Flood Control District.
LIDAR data also provide a basis for three-dimensional modeling of the
location of buildings, tanks, and equipment that could be used to
determine the optimal location for fire-fighting equipment at the same
refinery. The reach of a water jet can be placed against the 3-D model to
FEMA's Strategy for Map Modernization Shows Promise, but Challenges
Remain
determine the extent of coverage and identify obscured structures in the
"shadow" of other structures that would limit or block the reach of the
water jet. This same 3-D model could also be used in a vulnerability
analysis to locate potential targets within a given area that are at risk
from gunfire or hand-held rockets.
FEMA's strategy for managing map modernization is intended to support the
achievement of the expected program benefits of improved flood mitigation,
increased NFIP insurance participation, and improved multihazard
mitigation and risk management capabilities. However, FEMA's approach to
implementing the strategy poses several challenges that could hamper the
agency's efforts. FEMA's approach is based on four objectives. Two
objectives FEMA hopes to achieve through map modernization- building and
maintaining a premier data collection and delivery system and expanding
outreach and better informing the user community-have the potential to
improve the use of flood maps for improved flood mitigation and increased
NFIP participation, as well as multi-hazard risk management. The other two
objectives-building and maintaining mutually beneficial partnerships and
achieving effective program management-are intended to facilitate the
achievement of the first two objectives and their intended benefits
efficiently and effectively. Table 1 provides a brief description of
FEMA's four objectives for map modernization and the challenges facing
implementation.
Table 1: FEMA's Objectives for Map Modernization and Our Observations on the
Objectives and Challenges
Objective Description GAO Observations
Establish and maintain a premier data collection and delivery system
Create a GIS- and Internet-based system that provides easy access to
reliable flood hazard data and other data collected during the mapping
process. The system will be available to states and communities to input
and use data, therefore, enabling easier and less time-consuming data
maintenance and the use of the information for multi-hazard risk
management purposes. FEMA has ranked the nation's counties based on risk.
However, FEMA has not yet established data collection and analysis
standards for communities with similar risk. Without such standards, FEMA
cannot ensure that the level of data collection and analysis is consistent
across all communities with similar risk.
Expand outreach and better inform the Raise the awareness of flood map
users FEMA's outreach strategy is based on a
user community of their risk of flooding through increased recognition
that it has no direct authority to outreach efforts and educate the public
on ensure that many map modernization how they can use flood maps and
other benefits are achieved, but must rely on hazard data to mitigate
natural and man-others-e.g., mitigation efforts by individual made
disasters. property owners and lender enforcement of mandatory flood
insurance purchase.
Build and maintain mutually beneficial partnerships
Develop strategies for forming and enhancing relationships with all states
and communities resulting in their active participation in the production
of flood hazard data. This is intended to help improve the long-term
quality of flood data, ensure that the maps meet local needs, and
capitalize on local and regional knowledge and resources to achieve the
effective production and efficient use of flood maps at a reduced cost to
the federal government.
States and communities with limited resources and technical capabilities
are likely to pose a challenge to FEMA's ability to fund and implement
mapping activities. FEMA has not yet developed a strategy for how to
partner with communities that do not have the resources, capabilities, or
motivation to initiate and sustain mapping activities.
Using current staffing levels, FEMA may be challenged to effectively
oversee the contract and the map modernization program. In addition,
although FEMA has established measures to assess achievement of its
program objectives, its measures for its objectives to develop a premier
data system and to expand outreach and better inform the user community
are not clearly defined or fully developed.
Achieve effective program management Develop a flexible program
management structure that clearly evaluates the program's performance and
identifies continuous improvement strategies to most effectively and
efficiently conduct mapping activities that result in highquality flood
maps.
Source: GAO analysis.
In Its Efforts to Establish a The goal of FEMA's objective to develop a
new data system using the New Data System, FEMA latest technology is more
efficient production, delivery and, thereby, the Has Not Yet Established
use of flood maps. As discussed previously, FEMA hopes to accomplish Data
Standards for this by using geographic information systems technology that
provides the
foundation for the production and delivery of more accurate digital
floodDifferent Levels of Risk maps and multi-hazard data that is more
accessible over the Internet.
In developing the new data system to update flood maps across the nation,
FEMA's intent is to develop and incorporate flood risk data that are of a
level of specificity and accuracy commensurate with communities' relative
flood risks. According to FEMA, there is a direct relationship between the
types, quantity, and detail of the data and analysis used for map
development and the costs associated with obtaining and analyzing those
data. FEMA believes it needs to strike a balance between the relative
flood risk faced by individual communities and the level of analysis and
effort needed to develop reliable flood hazard data if it is to update the
nation's maps efficiently and effectively.
FEMA has ranked all 3,146 counties from highest to lowest based on a
number of factors, including, among other things, population, growth
trends, housing units, flood insurance policies and claims, repetitive
loss properties, and flood disasters. On the basis of this ranking, FEMA
established mapping priorities. However, FEMA has not yet established
standards on the appropriate data and level of analysis required to
develop maps based on risk level. FEMA has historically applied the same
minimum standards for all flood maps and supporting data.13 FEMA's
Guidelines and Specifications for Flood Hazard Mapping Partners
provides guidance for selecting the level of analysis and effort to
produce flood hazard data and have generally been used on a case-by-case
basis.14 The guidelines do not specify standards to be used for all
mapping projects within a given risk category. Without establishing
standards for different categories of risk, FEMA cannot ensure that it
uses the same level of data collection and analysis across all communities
within the same risk category. These standards could also provide a
consistent basis for estimating the costs of developing maps in each risk
category. According to FEMA, the agency plans to develop standards that
can be applied to different levels of flood risk as part of a 5-year map
modernization implementation plan. FEMA expects this plan to be completed
by the end of fiscal year 2004; however, at the time of our review, FEMA
had not yet developed draft standards or incorporated this task into its
implementation plan.
13For example, FEMA implemented digital base map standards in 1998 and
LIDAR standards in 2000.
14These guidelines describe detailed methods of analysis used for
high-risk areas and less detailed methods used in low-risk areas.
FEMA's Objective to Expand Outreach Efforts Recognizes the Agency Must Rely
on Others to Achieve Map Modernization Benefits
FEMA's objective to expand the scope and frequency of its outreach efforts
is intended to increase community and public acceptance of revised maps
and use of those maps. Historically, FEMA has only contacted communities
when initiating remapping and again when preliminary maps are completed.
These expanded outreach efforts reflect FEMA's understanding that it is
dependent on others to achieve the benefits of map modernization. For
example, under the structure of the NFIP, FEMA is dependent on communities
to adopt and enforce FEMA's minimum building standards and on mortgage
lenders to ensure compliance with mandatory flood insurance purchase
requirements. To expand the scope of its outreach efforts, FEMA plans to
involve a wide variety of community participants-e.g., mayors, emergency
managers, lenders, property owners, insurance agents, and developers-in
the mapping process. To expand the frequency of outreach, FEMA intends to
increase community involvement, awareness, and participation throughout
the entire flood mapping process. Through a continual education process,
FEMA's goal is to inform property owners and others potentially affected
by remapping efforts of steps they can take to mitigate the risk of
flooding, the types of damage and costs caused by flooding, and the
benefits of flood insurance.
According to FEMA, if a community is involved in and understands the map
modernization process, the community is more likely to accept and trust
the accuracy of the final, revised maps and is more likely to use the
maps' hazard data to mitigate natural and man-made disasters. Conversely,
if affected property owners do not understand why their communities are
being mapped (or remapped) or why their property is now in a flood zone,
the unexpected additional expense of new or increased flood insurance
premiums can form the basis of significant community opposition to map
modernization activities and lead to formal appeals, litigation, and
delays in implementing map changes.
We visited several communities that have nearly completed or are engaged
in revising flood maps and talked with relevant officials about recent
mapping projects and the importance of outreach efforts. The experience of
Pinellas County, Florida, shows the potential consequences of a limited
outreach effort while the experiences of the Harris County Flood Control
District in Houston, Texas, and Hillsborough County, Florida, show the
potential benefits of a more expanded outreach strategy.
Pinellas County, Florida Officials in Pinellas County, Florida, rejected
revised flood hazard maps developed by FEMA that raised base flood level
elevations and placed
Harris County, Houston, Texas
Hillsborough County, Florida
areas in newly established flood zones. According to community and FEMA
officials, FEMA did little to communicate with the community and the
public during the mapping process. According to FEMA, the agency was only
required to inform the community when the remapping project was initiated
in 1993 and again after the proposed maps were completed and provided to
the community for comment in December 1997. County officials subsequently
appealed the preliminary maps. According to local officials, expanded
outreach efforts by FEMA throughout this process could have helped the
community understand why the county was being mapped and how the new maps
reflected the true flood risks of the properties shown in revised flood
zones. After working closely with FEMA and mapping contractor officials,
the community finally accepted and implemented the maps by establishing
new building standards in September 2003.
The Harris County Flood Control District in Houston, Texas, took steps to
expand stakeholder and community outreach by releasing up to date flood
hazard map information on its Web site (http://www.tsarp.org). County
officials have also worked closely with the local newspaper to release
information on the updated flood hazard information to the public. In
addition, the county has held individual meetings with the county's 35
flood plain managers to ensure that they understood the new flood maps and
were able to convey that information to citizens; hired a public relations
consultant to provide guidance on how to better utilize the media to
disseminate flood map information; and conducted a poll survey to
ascertain public opinion about flood hazard risk and to develop strategies
to better convey flood hazard information. County officials also developed
several committee groups to relay flood maps information that is
audience-specific, such as a technical discussion group that reviews
technical issues related to revising the flood maps and verifies
methodological assumptions.
Hillsborough County officials have conducted extensive outreach while
continuing to work with FEMA throughout the remapping process. To help
ensure that insurance companies, real estate agents, county workers, and
citizens utilize flood maps in a more efficient and effective manner, a
stakeholders outreach coalition was formed in March of 2003. The purpose
of this coalition is to create an information campaign for individual
property owners and businesses that will be directly impacted by the new
maps. The coalition includes representatives from the county's Citizen
Advisory Committee, the insurance industry, real estate brokers, builders,
lenders, engineers, surveyors, and various county departments.
Hillsborough County is working in cooperation with FEMA to have final
maps in late 2004 and create a successful outreach program that could be
duplicated throughout the nation.
FEMA's expanded outreach efforts are intended to educate the public of the
potential flood risk in communities and to encourage them to take action.
Communities that participate in the NFIP are required to establish
floodplain management ordinances that require new and substantially
improved structures in newly designated floodplains to meet NFIP building
standards. However, if a property was not located in the floodplain in the
old map, but is in the floodplain in the new revised map, NFIP floodplain
management regulations do not require those owners to implement mitigation
measures unless they make substantial improvements to the structure.15
FEMA cannot compel affected property owners to take steps to mitigate
their properties against flood risks or to purchase flood insurance. Under
current notification requirements, federally regulated lenders, not FEMA,
serve as the primary channel for notifying property owners whose mortgaged
properties are subject to flood insurance requirements. When property
owners seek new financing-through purchase or refinancing-federally
regulated mortgage lenders are required to determine if the property is in
the floodplain, and, if so, require the purchase of flood insurance.
Lenders are not required to monitor map changes or to notify property
owners with existing mortgages whose properties are identified in a
floodplain by remapping if they are not aware of the change in status.16
Nonetheless, if federally regulated lenders become aware of flood map
changes that affect properties for which they hold mortgages through FEMA
notifications or flood zone determination companies,17 then they must
notify the property owner and require the purchase of flood insurance. The
information that must be provided to property owners is
15If a community determines that the cost of improvements to a home or
business equals or exceeds 50 percent of the market value of the building,
the building is considered a "substantial improvement" and must meet the
NFIP's minimum requirements.
16In making loans, federally regulated lenders are required to ensure that
property owners purchase flood insurance if their mortgages are secured by
a structure located in a floodplain. Lenders are also required to check
the flood hazard status of a property when triggered by statutory
tripwires, such as loan renewal or extension.
17Many lenders use flood zone determination companies to determine whether
properties require flood insurance as a result of loan origination, loan
assumption, or map changes. These companies use FEMA flood maps and other
data to ascertain if properties are situated in flood zones.
limited to notifying property owners that their structure is in a
floodplain, providing a definition of a flood plain, and requiring the
purchase of flood insurance if they live in a participating NFIP
community. As a result, FEMA's outreach efforts are important for
supplementing the formal requirements for notifying communities and
property owners of map changes.
FEMA's Strategy for Partnering with States and Local Communities Does Not
Include Communities with Few Resources to Assist in Flood Mapping
FEMA's objective for building and maintaining mutually beneficial
partnerships is intended to facilitate and support the efficient
production and effective use of flood maps. According to FEMA, local,
state, and federal partners that have invested resources and assisted in
managing mapping activities have the potential to positively affect the
detail, accuracy, and quantity of the data collected and improve how these
data are used. As part of their strategy for partnering, FEMA provides
guidance to the states on how to develop "business plans" that document
planned efforts to develop states' and communities' capability and
capacity to oversee the collection, analysis, and implementation of flood
data in their state and community and to justify funding for these
efforts. According to FEMA, 38 states have begun drafting such plans. FEMA
intends to use these state business plans to help prioritize its
continuing efforts to develop map modernization partners.
Through its Cooperating Technical Partners (CTP) program, FEMA has
developed partnerships with a variety of states and communities that have
developed their own data and provided their own funds to help update local
flood maps. Since 2000, FEMA has leveraged millions of dollars in funding
from 171 partners (states and local communities) for producing maps
through its CTP program. For example, from fiscal years 2000 to 2002, FEMA
used $70 million of its federal map modernization funding along with state
and local funds to develop what FEMA has estimated to be more than $155
million worth of new mapping data. Figure 12 compares FEMA's cumulative
funding for new mapping data through the CTP program with the total
cumulative dollar value of data produced with partner contributions since
the program was established in 2000.
Figure 12: Comparison of Cumulative FEMA Funding for Mapping Data with the
Total Cumulative Dollar Value of Mapping Data Produced through CTP Program
Dollars (in millions) 200
150
100
50
0 2000 2001 2002 Year
Cumulative FEMA funding for new mapping data Total cumulative dollar value
of data produced with partner contributions Source: FEMA.
According to FEMA, partnering has other benefits as well. For example, in
the long-term, those states and communities with whom FEMA has established
partnerships may be more likely to accept final map changes, expand their
capabilities, and assume greater responsibility for
periodically developing and incorporating updated flood data, resulting in
cost savings to FEMA. FEMA's partnership with the state of North Carolina
provides an example of a state assuming greater responsibility for
producing and maintaining flood maps.
FEMA's Cooperating Technical Partnership with the State of North Carolina
According to North Carolina officials, the devastating flooding and
subsequent damage that occurred from Hurricane Floyd in 1999 led the state
of North Carolina to take action to address the limitations of the
existing FEMA flood maps. Approximately 80 percent of the homes damaged or
destroyed during Hurricane Floyd were not depicted in the floodplain on
the state's flood maps. In 2000, North Carolina became the first
Cooperating Technical State under FEMA's CTP program, agreeing to assume
primary ownership and responsibility of flood maps for all North Carolina
communities. Since then, according to state floodplain mapping officials,
the state has contributed approximately $41 million towards the overall
floodplain mapping program. On the basis of this amount, North Carolina
has covered approximately 65 percent of the total cost to date for the
remapping effort. To date, 8 counties had received new effective flood
maps and 28 counties received new preliminary maps, which are now under
community review. (See fig. 13.)
Source: North Carolina Floodplain Mapping Program.
Some states and communities with few resources and technical capacities or
little history of flood mapping activities are likely to pose a challenge
to FEMA's ability to fund and implement mapping activities. For example,
we talked with flood management officials in several smaller communities
in Montgomery County, Texas; Santa Cruz County, Arizona; and Larkspur,
Colorado. These officials said that their communities lacked either the
funding needed to develop flood data, the technological capability to
develop digital flood data and use geospatial information systems, or, in
some cases, the community support needed to conduct mapping activities.
One approach for obtaining additional resources, capabilities, and
community support would be for FEMA to facilitate coordination with other
agencies within the state that have a stake in, or could benefit from,
mapping activities. For example, state departments of transportation can
benefit from information in FEMA's geospatial information system, such as
elevation data, in developing and implementing state roads and bridges.
North Carolina was able to get its state transportation department to help
fund the development of elevation data used for flood maps. FEMA has not
yet developed a strategy for how to partner with communities that do not
have the resources, capabilities, or motivation to initiate and sustain
mapping activities. Such a strategy could focus on how to assist these
potential partners in garnering community resources and developing
technological capabilities, how to coordinate with other agencies in their
state, and how to integrate these efforts with FEMA's community outreach
efforts to gain community support for mapping activities.
New Program Management Contract Is Performance-Based, but FEMA May Have
Difficulty Overseeing the Contract and Measuring Achievement of Program
Objectives
In March 2004, FEMA awarded a performance-based contract to obtain
assistance from a nationwide mapping contractor to manage tasks associated
with the significant expansion of the map modernization program. Unlike
many traditional government service contracts, which emphasize inputs
rather than outcomes, a performance-based contracting approach gives the
contractor the flexibility to determine how best to achieve the outcomes
and links payment to the contractor's ability to achieve these outcomes-an
approach supported by our past work in federal contracting. Overseeing
these types of contracts requires agency staff with the knowledge, skills,
and abilities to monitor the contractor's efforts using performance
measures that accurately measure agreed-upon outcomes.
FEMA may be limited in its ability to effectively manage the contract, as
well as the significant expansion of tasks associated with a five fold
increase in funding and related mapping activities that will continue to
be performed by agency staff. These tasks include managing grants for many
new mapping partners and administering contracts with independent firms to
develop and process a significantly larger quantity of flood data to
support local efforts. A staffing needs assessment completed by FEMA in
December 2003 identifies a need for an additional 75 staff with additional
skills, including contracting and program management capabilities. In
appropriating fiscal year 2004 map modernization funds, Congress included
a provision that would allow FEMA to use up to 3 percent, or $6 million,
for administrative purposes. As of March 2004, FEMA had filled 1 of the 75
positions by reallocating existing resources. According to FEMA, it plans
to fill another 33 positions using the administrative funding identified
in the fiscal year 2004 budget. In addition, FEMA also plans to fill an
additional 10 positions by moving staff from other FEMA departments or
filling vacancies. However, at the time of our review,
FEMA had not yet established a plan for filling the remaining 31
headquarters and regional positions.
One element of effective program management is establishing performance
measures to determine how well FEMA is achieving its map modernization
program objectives. FEMA has established performance measures for all four
of its program objectives. However, FEMA's measures for two of those
objectives that directly support the use of flood maps for risk
management-to develop a premier data system and to expand and better
inform the user community are not clearly defined or fully developed.
FEMA's principal measure for developing and maintaining a premier data
collection and delivery system is the percent of the national population
with community-adopted, GIS data-based flood maps. However, this measure
does not indicate whether the maps themselves meet any FEMAestablished
standards for accuracy. As noted earlier, FEMA has not yet defined the
minimum level of data collection and analysis for communities with similar
risk.
To measure the progress and success of expanding and better informing the
user community, FEMA established performance measures related to the
percent increase in communities' awareness and use of new maps. FEMA plans
to use surveys as the primary means of measuring increased community
awareness and use of the new maps. However, FEMA has not yet fully
developed an operational definition of how it plans to measure "awareness"
or "use," for example, that reflect mitigation steps taken or the purchase
of flood insurance. Because the link between revising maps and the use of
maps in terms of increased NFIP participation is not direct, we recognize
that it may be a challenge to develop a performance measure that
accurately reflects the impact on NFIP participation rates of efforts to
expand and improve outreach. Nonetheless, without developing such a
measure (or measures), FEMA will be less able to ensure that its map
modernization program will have resulted in one of FEMA's primary intended
benefits.
Conclusions FEMA's map modernization strategy recognizes the limits of
the agency's authority to directly achieve such key intended map
modernization benefits as increased, effective flood mitigation efforts
and increased flood insurance participation rates by property owners whose
properties are within the most hazardous flood areas-those in which there
is at least a 1 percent chance of flooding in any given year. At the same
time, FEMA recognizes that it has finite resources for completing map
modernization
and needs to leverage its resources with assistance from state and local
communities. Both the credibility of the maps as accurate and useful and
stakeholders' understanding of how the maps can be used to reduce flood
risk and flood damage will be instrumental in enhancing the probability
that the maps will be used to achieve their intended benefits.
FEMA's outreach strategy for involving stakeholders in map modernization
appears to be reasonable. Even with these outreach efforts, the
credibility and likely use of the maps can be compromised if there is a
perception that similar communities are not treated similarly during map
modernization. Establishing and implementing data collection and analysis
standards for communities with similar risk can help to assure communities
that map development for all communities within the same risk category
will be consistent and comparable. Such standards can also help FEMA to
target its map modernization resources more efficiently by matching the
level of data collection and analysis with the level of flood risk.
Similarly, by developing strategies for partnering with state, and local
flood management stakeholders with lower levels of capabilities and
resources, FEMA will be better able to leverage available resources and
identify the most effective approaches to engaging its partners in the
remapping process.
To the extent that FEMA does not have appropriate numbers of staff with
the requisite skills, it may have limited ability to provide effective
monitoring and oversight of its new performance-based contract, whose
contractor has been charged with much of the day-to-day work of map
modernization that formerly FEMA performed. Finally, in some cases, the
performance measures established for the program and the contractor may
not be sufficient to permit FEMA to measure whether map modernization is
achieving its intended benefits. Without useful operational definitions
for its planned surveys to measure map acceptance and use, FEMA cannot
reasonably measure and demonstrate whether map modernization has achieved
its intended benefits in such areas as community and individual flood
mitigation efforts or increased flood insurance purchase rates.
Recommendations To help ensure that FEMA's map modernization achieves the
intended benefits of improved flood mitigation, increased flood insurance
participation, and improved multi-hazard mitigation and risk management
capabilities through the production of more accurate and accessible flood
maps, we recommend that the Secretary of Homeland Security direct the
Undersecretary of Emergency Preparedness and Response to take the
following four actions:
Agency Comments
o Develop and implement data standards that will enable FEMA, its
contractor, and its state and local partners to identify and use
consistent data collection and analysis methods for communities with
similar risk.
o Develop and implement strategies for partnering with state and local
entities with varying levels of capabilities and resources.
o Ensure that it has the staff capacity to effectively implement the
nationwide mapping contract and the overall map modernization program.
o Develop and implement useful performance measures that define FEMA' s
progress in increasing stakeholders' awareness and use of the new maps,
including improved mitigation efforts and increased participation rates in
purchasing flood insurance.
We provided a draft of this report to DHS for its review and comment. We
met with DHS and FEMA officials, including FEMA's Mitigation Division
Acting Deputy Director, to discuss the report. In providing oral comments,
DHS and FEMA generally agreed with the report's contents and provided us
with minor technical comments, which we have incorporated where
appropriate. In addition, DHS and FEMA generally agreed with our
recommendations and provided the following comments:
o To address the data standard recommendation, FEMA said that it plans
to refine existing standards, in coordination with stakeholders, to ensure
consistent data collection and analysis for all communities commensurate
with their flood risk.
o To address the recommendation concerning partnering strategies to
address varying levels of capabilities and resources, FEMA said that it
would continue to collaborate with stakeholder groups to develop an
effective strategy to include states and communities with varying levels
of capabilities and resources.
o To address the recommendation to ensure that the agency has the staff
capacity to effectively implement map modernization and oversee the
contract, FEMA said that it has begun to take steps not only to fill 44
positions for fiscal year 2004, as noted in the report, but is also
developing a plan to ensure that additional staffing needs are met in
fiscal year 2005 and beyond.
o To address the recommendation to develop and implement performance
measures for increasing stakeholders' awareness and use of flood maps,
FEMA said that it plans to refine performance measures
for this map modernization objective to make them more useful and
quantifiable.
We will send copies of this report to the Secretary of Homeland Security.
We will also make copies available to others upon request. In addition,
this
report will be available at no charge on GAO's Web site at
http://www.gao.gov. If you or your staff have any questions about this
report, please contact me at (202) 512-8777 or at [email protected].
Major contributors to this report are listed in appendix III.
Sincerely yours,
William O. Jenkins, Jr.
Director, Homeland Security and Justice Issues
Appendix I: Objectives, Scope, and Methodology
To describe how map modernization is intended to improve the accuracy and
accessibility of the nation's flood maps, we interviewed Federal Emergency
Management Agency (FEMA) headquarters officials and agency officials in
three of the regional offices: Region IV in Atlanta, Georgia; Region VIII
in Denver, Colorado; and Region VI in Denton, Texas. To assess the
reliability of FEMA's data regarding the number and age of the nation's
flood maps, we interviewed officials knowledgeable about the data and the
systems that produced them and determined that the data were sufficiently
reliable for the purposes of this report. We also reviewed key FEMA
documents that describe how map modernization is intended to use advanced
technology to improve the accuracy and accessibility of flood maps.
Realizing that map modernization is in the early stages of implementation
and information on its impact is limited, we conducted site visits in
states and communities that have already begun to modernize their flood
maps. To identify potential locations for site visits, we spoke with FEMA
Mitigation Division officials and representatives from the following
professional organizations: Association of State Flood Plain Managers,
National Association of Flood and Stormwater Management Agencies, National
Emergency Management Association, and the Mapping Coalition. The selected
site visits represent areas that have recently experienced considerable
population growth, a high National Flood Insurance Program (NFIP) base, or
a high number of repetitive flood loss claims. Over 64 percent of all NFIP
policies are located in the states selected for site visits, and over 40
percent of all repetitive loss properties are located in the states in
which we conducted site visits.
Our site visits involved reviewing key documents, graphics, and other
information related to our reporting objectives. Site visits included the
following locations:
o Hillsborough, Sarasota, and Pinellas counties of Southwest Florida
o Maricopa County, Arizona
o State of North Carolina
o Mecklenburg County, North Carolina
o Harris County, Texas
o State of Colorado
To describe the expected benefits of map modernization, we interviewed
FEMA officials in their Mitigation Division in Washington, D.C., and
obtained documents and graphics from FEMA officials describing the
benefits the agency expects to result from map modernization activities.
Appendix I: Objectives, Scope, and Methodology
We also interviewed state and local officials on the potential
multi-hazard benefits of map modernization and obtained documents and
graphics illustrating the expected benefits.
To determine the extent to which FEMA's strategy for managing the map
modernization program supports the achievement of the expected benefits of
more accurate and accessible maps, we first reviewed previous documents
published by FEMA and others on map modernization. Throughout our review,
we remained in constant contact with FEMA officials in their Mitigation
Division to monitor the development of FEMA's prioritization of fiscal
year 2003 funded mapping projects and the implementation of the overall
map modernization approach.
To identify areas where FEMA's implementation of map modernization is
limited, we gathered and synthesized the experiences and challenges
identified through documentation and interviews provided from various
sources, including:
o FEMA headquarters and regional officials;
o site visits and selective review participants;
o professionals in the Association of State Floodplain Managers,
National Association of Stormwater Management Agencies, the National
Emergency Management Agency, and Arizona Association of Floodplain
Managers; and
o private industry representatives in the fields of flood zone
determinations, engineering, technology and program consulting, real
estate sales and development, and home mortgage lending.
We also conducted additional research to determine whether limitations
existed in FEMA's implementation of its outreach approach for its map
modernization program. We obtained information on the roles and
responsibilities of FEMA and lenders to communicate changes in flood
hazard status. We also reviewed and synthesized applicable laws,
regulations, and guidance regarding notification of flood hazard risk to
identify all parties designated to inform property owners of changes in
the flood hazard maps. We interviewed FEMA mapping and insurance
officials, state, community, and National Flood Determination Association
officials as well as conducted site visits to ascertain information on
current processes for communicating changes in flood hazard status.
Additionally, we interviewed FEMA's general counsel to obtain the agency's
position on statutory requirements for notification of property owners
after remapping.
Appendix I: Objectives, Scope, and Methodology
To further analyze the strengths and limitations of FEMA's implementation
approach, we also reviewed FEMA's Inspector General's reports related to
flood mapping and reviewed our previous work and guidance in the areas of
performance-based contracting and performance measurement that relate to
the objectives of map modernization.
The information regarding deaths and damages due to floods was considered
background information and was not verified. We conducted our review from
April 2003 through March 2004 in accordance with generally accepted
government auditing standards.
Appendix II: Users of Flood Maps
The principal stakeholders that use FEMA flood maps and the nature of
their use are described in this appendix.
State and local floodplain managers/community planners: use flood maps to
make floodplain management decisions for each of the nearly 2 million
development permits issued for new structures nearly 20,000 NFIP
participating communities that have maps. They are responsible for
establishing and enforcing land-use and construction ordinances that
comply with minimum NFIP standards.
Insurance companies and agents: use flood maps to determine actuarial
rates for flood insurance policies. Private insurance companies that sell
NFIP-backed flood insurance use the flood maps to determine the proper
premium rate for a flood insurance policy. There are approximately 250,000
new policies rated and sold each year.
Lenders: use flood maps to determine the flood risk status of mortgaged
properties at loan origination and through the entire life of the
mortgage. Each of the 10 to 15 million federally related mortgage
transactions each year requires that the flood maps be consulted to
determine whether the structure secured by the loan is located in the
floodplain on the current flood map.
Flood zone determination companies: use flood maps to determine property
locations relative to flood hazard areas on behalf of mortgage lenders
that typically contract this service to companies with expertise in making
flood zone determinations and the capability to make many determinations
quickly.
Individual property owners: use flood maps to better understand their
flood risk status.
Land developers: use flood maps to assist in designing developments that
are safe from flood hazards.
Surveyors: use flood maps to prepare elevation certificates for
structures. These help owners determine their flood risk by comparing the
mapped flood elevations to the building's lowest floor elevation.
Engineers: use flood maps when designing flood mitigation projects and to
site and design new buildings and infrastructure.
Appendix II: Users of Flood Maps
Real estate professionals: use flood maps to determine the flood risk
status of properties in the community.
State and local disaster and emergency response officials: use flood maps
to prepare for all disasters, issue hazard warnings, and implement
emergency response activities and aid in the rebuilding and reconstruction
phases.
Other federal agencies: use flood maps in implementing Executive Order
11988, Floodplain Management, for federal actions proposed in or affecting
floodplains.
Appendix III: GAO Contacts and Staff Acknowledgments
GAO Contacts
Staff Acknowledgments
(440190)
William O. Jenkins, Jr. (202) 512-8777 Christopher Keisling (404) 679-1917
In addition to those named above, Mark Abraham, Leo Barbour, Mark Braza,
Grace Coleman, Christine Davis, Michelle Fejfar, Brian James, Kirk
Kiester, and Meg Ullengren made key contributions to the report.
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