Flood Map Modernization: Federal Emergency Management Agency's	 
Implementation of a National Strategy (12-JUL-05, GAO-05-894T).  
                                                                 
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 resulted in  
approximately $55 billion in damages. The Federal Emergency	 
Management Agency (FEMA) is responsible for managing the National
Flood Insurance Program (NFIP). The program uses flood maps to	 
identify the areas at greatest risk of flooding and make	 
insurance available to property owners to protect themselves from
flood losses. According to FEMA, many of the nation's flood maps 
are more than 10 years old and no longer reflect current flood	 
hazard risks because of erosion and changes in drainage patterns.
Moreover, because many flood maps were created or last updated,  
there have been improvements in the techniques for assessing and 
displaying flood risks. This testimony is based on GAO's findings
and recommendations in its March 2004 report related to (1) how  
map modernization intended to improve the accuracy and		 
accessibility of the nation's flood maps, (2) what the expected  
benefits of more accurate and accessible flood maps are, and (3) 
to what extent FEMA's strategy for managing the map modernization
program support the achievement of these benefits.		 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-894T					        
    ACCNO:   A29558						        
  TITLE:     Flood Map Modernization: Federal Emergency Management    
Agency's Implementation of a National Strategy			 
     DATE:   07/12/2005 
  SUBJECT:   Data collection					 
	     Data integrity					 
	     Flood control					 
	     Flood control management				 
	     Floods						 
	     Geographic information systems			 
	     Standards						 
	     Strategic planning 				 
	     Flood insurance					 
	     Intergovernmental relations			 
	     Maps						 
	     FEMA Multi-Year Flood Hazard			 
	     Identification Plan				 
                                                                 
	     FEMA National Flood Insurance Program		 

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GAO-05-894T

United States Government Accountability Office

GAO Testimony

Before the Subcommittee on Housing and Community Opportunity, Committee on
Financial Services, House of Representatives

For Release on Delivery Expected at 10:00 a.m. EDT Tuesday, July 12, 2005

FLOOD MAP MODERNIZATION

  Federal Emergency Management Agency's Implementation of a National Strategy

Statement of William O. Jenkins, Jr., Director Homeland Security and Justice
Issues

GAO-05-894T

[IMG]

July 2005

FLOOD MAP MODERNIZATION

Federal Emergency Management Agency's Implementation of a National Strategy

  What GAO Found

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 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.

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 manmade.

At the time of GAO's review, FEMA had not yet established clear standards
for the types, quantity, and specificity of data collection and analysis
associated with different levels of flood risk. We recommended that FEMA
develop standards to 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. In November 2004, FEMA
issued its Multi-Year Flood Hazard Identification Plan. The plan describes
FEMA's strategy for addressing GAO's recommendation by using varying types
of data collection and analysis techniques to develop flood hazard data in
order to relate the level of study and level of risk for each county. .
GAO concluded that FEMA's performance measures would not effectively
measure the extent to which the agency's map modernization program would
result in its primary intended benefits. As a result, GAO recommended that
FEMA develop and implement useful performance measures. In response to
GAO's recommendation, FEMA has set target percentages in its Multi-Year
Flood Hazard Identification Plan for four key performance indicators in
fiscal years 2006 through 2009. FEMA's four indicators are (1) Population
with Digital GIS Flood Data Available Online, (2) Population with Adopted
Maps that Meet Quality Standards, (3) Percent of Effort Leveraged; that
is, state and local resources provided for map modernization as a
percentage of FEMA resources provided, and (4) Appropriated Funds Sent to
Coordinating Technical Partners.

                 United States Government Accountability Office

Mr. Chairman and Members of the Subcommittee:

I appreciate the opportunity to participate in today's hearing to discuss
the Federal Emergency Management Agency's (FEMA) national flood map
modernization program.1 My testimony is primarily based on our March 2004
report on FEMA's map modernization efforts.2

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.3 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
mitigation4 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. 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.

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
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

1Prior 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.

2 GAO, Flood Map Modernization: Program Strategy Shows Promise, but
Challenges Remain, GAO-04-417, (Washington, D.C.: March 31, 2004)

3Data are from the U.S. Army Corps of Engineers in cooperation with the
National Weather Service.

4 Mitigation 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.

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,5 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.

With congressional support and funding, last year FEMA embarked on a $1
billion, 5-year effort to update the nation's flood maps. Today, I am here
to discuss the findings and recommendations of our March 2004 report. My
remarks today will focus on (1) how map modernization is intended to
improve the accuracy and accessibility of the nation's flood maps; (2)
what the expected benefits of more accurate and accessible flood maps are;
and (3) to what extent FEMA's strategy for managing the map modernization
program supports the achievement of these benefits.

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
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.

5 See 42 U.S.C. 4001 et seq.

                                    Summary

In summary, we found:

o  	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 (GIS) 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 were more than 10 years old at the time of
our review. Many of these maps no longer reflect current flood hazard
risks because changes such as erosion and development 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.

o  	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.

o  	FEMA's strategy for managing map modernization is designed to support
the expected program benefits, but FEMA's approach to implementing the
strategy raised several concerns that we concluded 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, at the time
of our review, FEMA had not yet established clear

standards for the types, quantity, and specificity of data collection and
analysis associated with different levels of flood risk. FEMA had 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 are 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, we concluded that FEMA could 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 acknowledged the need to develop such standards, but, at the
time of our review, had not yet developed draft standards or included this
task into its map modernization implementation plan. In November 2004,
FEMA issued its Multi-Year Flood Hazard Identification Plan. The plan
describes FEMA's strategy for addressing our concerns and discusses the
varying types of data collection and analysis techniques the agency plans
to use to develop flood hazard data in order to relate the level of study
and level of risk for each county.

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 protect 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 had developed a strategy for partnering with these
agencies to encourage greater involvement in map modernization, including
the contribution of resources. However, we concluded that the overall
effectiveness of the agency's partnering efforts was uncertain because
FEMA had not yet developed a clear strategy for partnering with
communities that have few resources, limited mapping capability, and
little history of flood mapping activities. FEMA's Multi-Year Flood Hazard
Identification Plan (the Plan) does not explicitly address such
strategies. For fiscal year 2004, the Plan notes that, nationwide, dollars
leveraged from local, non-FEMA sources substantially exceeded the target
level of 20 percent, with 36 percent of the effort leveraged from other
partners. In 4 of the 10 FEMA regions the leverage exceeded 40 percent.
However, in 3 of the 10 FEMA regions the leverage was less than 10
percent. This experience, along with a projected 50 percent increase in
the total cost of the program, supports the need for strategies to address
disparities and maximize map modernization stakeholders' contributions to
the program.

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 had determined that it
needed 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, and had developed plans to hire or
transfer 43 others, but had not yet determined how it would acquire the
remaining 31 positions. In addition, we found that FEMA had not clearly
defined performance measures related to whether (1) the revised maps meet
any established standards for accuracy and (2) outreach efforts are
successful in increasing the community and individual awareness and use of
flood maps. In response to our recommendation, FEMA's set goals in its
November 2004 Multi-Year Flood Hazard Identification Plan for key
performance indicators.

  Map Modernization Intends to Use Advanced Technologies to Produce More
  Accurate and Accessible Digital Flood Maps:

FEMA's four indicators are (1) Population with Digital GIS Flood Data
Available Online, (2) Population with Adopted Maps that Meet Quality
Standards, (3) Percent of Effort Leveraged; that is, state and local
resources provided for map modernization as a percentage of FEMA resources
provided, and (4) Appropriated Funds Sent to Cooperating Technical
Partners (CTP). To track its progress of map modernization annually, FEMA
set target percentages for achieving these performance indicators in
fiscal years 2006 through 2009.

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. 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. Prior to
fiscal year 2004, the $35 million to $50 million in annual flood insurance
policy fees had been the only source of funding for updating flood maps,
and according to FEMA, the agency had not been able to keep the maps
updated with the funds available. As a result, at the time of our review,
nearly 70 percent of the nation's approximately 92,222 flood maps6 were
more than 10 years old and many contain inaccurate data, according to
FEMA.

Over time, physical conditions in watersheds and floodplains can change,
and improvements in the techniques for assessing and displaying flood
risks are made. FEMA plans to use the latest technology, such as 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

6 The 92,222 flood maps represent nearly 20,000 communities.

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 had
established standards and graphic specifications for digital flood maps
created with GIS.

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.

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.

FEMA Expects Map Modernization to Increase the Likelihood Maps Will Be
Used for Risk Management

FEMA expects map modernization to increase the likelihood that the more
accurate and accessible maps will be used for risk management purposes.
Specifically, FEMA expects the new maps to be used to (1) improve flood
mitigation, (2) increase flood insurance participation, and (3) improve
"multi-hazard" mitigation and risk management capabilities. First, FEMA
expects communities to be able to use these new and revised maps to better
manage and mitigate flood risk by regulating floodplain development
through building codes, ordinances, and regulations. Second, 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. 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
man-made. 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.

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
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.

Map Modernization Is Expected to Help Increase Flood Insurance
Participation

Map modernization has the potential to help increase flood insurance
participation. The accuracy of the new maps should better identify at-risk
property owners who would be best served by obtaining flood insurance
whether or not the owners would be required to purchase insurance under
the NFIP's mandatory purchase requirement. Moreover, the digital, GISbased
maps should make flood risk information more accessible to a variety of
users such as lenders and community officials who could conduct targeted
outreach to these property owners.

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

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.

  FEMA's Strategy for Map Modernization Shows Promise, but Challenges Remain

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, in reviewing FEMA's
approach to implementing the strategy, we identified 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.

In Its Efforts to Establish a New Data System, FEMA Had Not Yet
Established Data Standards for Different Levels of Risk

The goal of FEMA's objective to develop a new data system using the latest
technology is more efficient production, delivery and, thereby, the use of
flood maps. As discussed previously, FEMA hopes to accomplish this by
using geographic information systems technology that provides the
foundation for the production and delivery of more accurate digital flood
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 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, at the time of our review, FEMA had not
established standards on the appropriate data and level of analysis
required to develop maps based on risk level. FEMA had historically

applied the same minimum standards for all flood maps and supporting
data.7 FEMA's Guidelines and Specifications for Flood Hazard Mapping
Partners provided guidance for selecting the level of analysis and effort
to produce flood hazard data and the guidelines had generally been used on
a case-by-case basis.8 We found that the guidelines do not specify
standards to be used for all mapping projects within a given risk category
and concluded that, without establishing standards for different
categories of risk, FEMA could not 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. At the time
of our review, FEMA had not yet developed draft standards or incorporated
this task into its implementation plan. As a result, we recommended that
FEMA develop and implement data standards that would 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.

In November 2004, FEMA issued its Multi-Year Flood Hazard Identification
Plan. The plan describes FEMA's strategy for updating flood maps used for
NFIP purposes and discusses the varying types of data collection and
analysis techniques the agency plans to use to develop flood hazard data
in order to relate the level of study and level of risk for each county.

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,

7For example, FEMA implemented digital base map standards in 1998 and
LIDAR standards in 2000.

8 These guidelines describe detailed methods of analysis used for
high-risk areas and less detailed methods used for low-risk areas.

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.

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.9 FEMA
cannot compel affected property owners to take steps to protect 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

9 If 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.

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.10

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,11 then they must
notify the property owner and require the purchase of flood insurance. The
information that must be provided to property owners is 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 had begun drafting such plans. FEMA
intends to use these state business plans to help prioritize its
continuing efforts to develop map modernization partners.

10 In 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.

11Many 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.

Through its 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. 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.

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 planning and building 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. At the time of our
review, FEMA had 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. As a result, we recommended that FEMA develop and implement
strategies for partnering with state and local entities with varying
levels of capabilities and resources. FEMA's Plan does not explicitly
address such strategies. For fiscal year 2004, the Plan notes that,

nationwide, dollars leveraged from local, non-FEMA sources substantially
exceeded the target level of 20 percent, with 36 percent of the effort
leveraged from other partners. In 4 of the 10 FEMA regions the leverage
exceeded 40 percent. However, in 3 of the 10 FEMA regions the leverage was
less than 10 percent. This experience, along with a projected 50 percent
increase in the total cost of the program, supports the need for
strategies to address disparities and maximize map modernization
stakeholders' contributions to the program.

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.

We concluded that FEMA might 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. At the time of our review FEMA planned to fill another 33
positions using the administrative funding identified in the fiscal year
2004 budget. In addition, FEMA also planned 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. As a result, we recommended that FEMA ensure that it has the

staff capacity to effectively implement the nationwide mapping contract
and the overall map modernization program.

One element of effective program management is establishing performance
measures to determine how well FEMA is achieving its map modernization
program objectives. FEMA had established performance measures for all four
of its program objectives. However, we concluded that 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 were 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 FEMA-established
standards for accuracy (because FEMA had 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 had 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 recognized
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), we concluded that FEMA would be less able to ensure
that its map modernization program will have resulted in one of FEMA's
primary intended benefits. As a result, we recommended that FEMA 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.

In response to our recommendation, FEMA's set goals in its November 2004
Multi-year Flood Hazard Identification Plan to improve public safety
through the availability of reliable flood risk data. Specifically, FEMA
plans to increase the safety for at least 85 percent of the U.S.
population through availability of accurate flood risk data in GIS format.
To achieve

this goal, FEMA has set targets for key performance indicators (KPI)
through fiscal year 2009 (production is scheduled for completion in fiscal
year 2010). FEMA's four KPIs are (1) Population with Digital GIS Flood
Data Available Online, (2) Population with Adopted Maps that Meet Quality
Standards, (3) Percent of Effort Leveraged; that is, state and local
resources provided for map modernization as a percentage of FEMA resources
provided, and (4) Appropriated Funds Sent to CTPs. To track its progress
of map modernization annually, FEMA set target percentages for achieving
these performance indicators in fiscal years 2006 through 2009.

  Contact and Staff Acknowledgements

(440438)

Mr. Chairman and Members of the Committee, this concludes my prepared
statement. I would be pleased to answer any questions you and the
Committee Members may have.

For further information about this statement, please contact William O.
Jenkins, Jr. Director, Homeland Security and Justice Issues on (202)
5128777 or [email protected]. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. GAO staff who made major contributors to this testimony
included Grace Coleman, Christopher Keisling, Raul Quintero, and John
Vocino.

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