not push this on state NFIP Coordinators, few if any programs could absorb this. This should be a separate statement. Dam Safety programs have nothing to do with CAP grants, LOMR submissions, etc. S.5. Redesign CAP and delegation programs One thing they need to do is adjust the grant cycle to emphasize building state and local capability for CAP-SSSE it is now out of sync, and states – instead of simply buying state services wait for 6-9 months into the year before they get an award for that year. They need to fund for – two years so that this grant can be in the same timeframe as the CTP grants. S. 6. Negotiate CAP participation individually with each state with each change of state administration, and require governor-level commitment from state, using many forms of federal funding as an incentive S.7. Same as to: States need to These are highly judgmental statements and not upgrade their entire programs: regulations, that accurate. More than 10 years ago I was coordination, policies on where state supported by this program and we negotiated the emergency management funds are spent, their workplans annually. I supported FEMA HQ on CAP mitigation efforts, etc. There should be some and it’s highly customized. Suggest reworking minimum standards for state programs, which these to positive tweaks rather than a negative ASFPM should work with states/feds to create and tone. Some states do not have the political will to promote. do what is suggested, but still implement strong NFIP support to local communities. S.8. Allow states to allocate up to 50% of CAP Don’t the fees come from flood insurance? If it is funding to state-selected non NFIP, but effective not NFIP it should not be funded! Unless I am flood loss reduction activities (not projects) missing something here! WHY NOT EFFECTIVE PROJECTS? such as education and outreach on other flood hazards. To ensure that these additional activities would be in keeping with the origination of the CAP funding (Flood Insurance Fund), these additional activities may need to be tied to flood insurance claims/loss reduction for the state. Recommendation to delete completely (x2): The funds to support CAP come from the fees associated with the sale of flood insurance. ASFPM should not support this recommendation. S.9. Tie CAP funding to NFIP and flood disaster reduction-related needs and add annual increases
not push this on state NFIP Coordinators, few if any programs could absorb this. This should be a separate statement. Dam Safety programs have nothing to do with CAP grants, LOMR submissions, etc. S.5. Redesign CAP and delegation programs to emphasize building state and local capability instead of simply buying state services One thing they need to do is adjust the grant cycle for CAP-SSSE – it is now out of sync, and states wait for 6-9 months into the year before they get an award – for that year. They need to fund for two years so that this grant can be in the same timeframe as the CTP grants. S. 6. Negotiate CAP participation individually with each state with each change of state administration, and require governor-level commitment from state, using many forms of federal funding as an incentive S.7. Same as to: States need to upgrade their entire programs: regulations, coordination, policies on where state emergency management funds are spent, their mitigation efforts, etc. There should be some minimum standards for state programs, which ASFPM should work with states/feds to create and promote. These are highly judgmental statements and not that accurate. More than 10 years ago I was supported by this program and we negotiated the workplans annually. I supported FEMA HQ on CAP and it’s highly customized. Suggest reworking these to positive tweaks rather than a negative tone. Some states do not have the political will to do what is suggested, but still implement strong NFIP support to local communities. S.8. Allow states to allocate up to 50% of CAP funding to state-selected non NFIP, but effective flood loss reduction activities (not projects) Don’t the fees come from flood insurance? If it is not NFIP it should not be funded! Unless I am missing something here! WHY NOT EFFECTIVE PROJECTS? such as education and outreach on other flood hazards. To ensure that these additional activities would be in keeping with the origination of the CAP funding (Flood Insurance Fund), these additional activities may need to be tied to flood insurance claims/loss reduction for the state. Recommendation to delete completely (x2): The funds to support CAP come from the fees associated with the sale of flood insurance. ASFPM should not support this recommendation. S.9. Tie CAP funding to NFIP and flood disaster reduction-related needs and add annual increases
NFPPR_CombinedComments_SectionS.docx