Community Rating System

March 24, 2006

It’s one thing for communities to create environmental policies, plans, and programs to meet state or federal mandates, but quite another to participate in a voluntary incentive program. But that is what many are doing through the Community Rating System (CRS), a 15-year-old program of the National Flood Insurance Program (NFIP), administered by the Federal Emergency Management Agency (FEMA).

CRS was started to encourage community floodplain management activities that exceed minimum NFIP standards. Participating communities’ property owners receive flood insurance premium rate adjustments because of the efforts to reduce flood risks.

Municipalities are rated in 10 classes, ranging from Class 1, which designates those having attained the most credit points–resulting in the largest insurance premium reduction–to Class 10, which receives no premium reductions. Rates are discounted in increments of 5%, with a Class 1 community receiving a 45% discount and a Class 9 receiving a 5% discount.

CRS encompasses 18 credit-earning activities organized under the categories of public information, mapping, regulations, flood damage reduction, and flood preparedness.

CRS represents a three-legged stool of floodplain management: mapping or identifying the flood hazard, regulating it through floodplain management, and flood insurance, says Bret Gates, FEMA’s Mitigation Division CRS coordinator for NFIP.

“Assuming the first two work, then they’ll offer insurance,” Gates says. “CRS is the “˜carrot’ with insurance discounts.”

Some 1,038 communities participate in CRS. “While you might say that is a small number, those CRS communities represent 67% of all the NFIP policyholders in the country,” says Gates. Collectively, they save more than $170 million in flood insurance discounts.

“It’s a revenue-neutral program,” Gates says. “We are not taxpayer funded. It is a redistribution of discounts, similar to what an insurance company would do when you get a good driver discount.”

CRS consultant Earl King believes CRS participation numbers are low because it’s a relatively new program and also that some cities “have either not taken the time to work on it or else have not seen the value of it.”

CRS communities praise the value it brings their citizens. For instance, the primary benefit Tulsa, OK–the highest-rated community in the nation at Class 2–derives is receiving the highest flood insurance discount in the nation, 40%. It also benefits from increased awareness of flood insurance and good press by being recognized as the best in the nation, says Brent Stout, senior special projects engineer in charge of stormwater planning with Tulsa’s Public Works Department. “We’re very proud of that and want to continue that tradition and move forward,” he says.

Washington’s King County flood insurance policyholders have derived the direct benefit of a 35% discount, saving each policyholder nearly $300 annually. King County is the only Class 3 county and is the nation’s highest-rated CRS county.

King County’s national recognition as the top-rated CRS county in the United States is not only good public relations, but good public policy as well, notes Steve Bleifuhs, manager of King County’s river and floodplain management program. “We can use that national recognition when applying for federal and state grants, to talk about our program and what we do,” he says. “It helps when talking to FEMA or other federal funding agencies for them to know we really are a proactive community, as demonstrated through our CRS activity, and our intent is truly to reduce the flood risk as opposed to trying to get money to do a study or something that hasn’t gone through a litmus test with the public.”

Earl King says CRS participation costs to a community are rather low compared to the return on the investment. For instance, the city for which he serves as assistant public works director–Hallandale Beach, FL–spends less than $10,000 on the program. Most costs center on information dissemination.

CRS involves a number of mitigation activities, including developing or providing accurate flood hazard information. “We need to move further along in updating maps, and that’s driven the map modernization effort,” Gates says. He says communities must move beyond what FEMA can provide.

“We are never going to have enough funds to provide the latest mapping information, especially with fast-growing communities and the high cost of surveying and getting hydrology information,” he adds.

Earl King says mapping is becoming more common with geographic information systems (GIS). “It’s becoming a usual thing to put the flood map on GIS and have it on your Web site,” he says. “People can know right away whether they’re in a flood zone.”

Bleifuhs notes that nonetheless, mapping can be expensive. King County is updating its floodplain maps, and with the number of rivers in the county, costs run between $10,000 and $20,000 per linear mile. Another concern, he says, is that the county faces a public perception that officials are trying to increase regulations or provide regulatory framework for managing somebody’s lands when they’re conducting floodplain map updates.

As part of its program, King County also is mapping channel migration hazards. “Some hazards are not just about flooding, but also about where rivers historically over time have been and where they would like to go in the future, as they naturally migrate,” he says. County officials examine old aerial photos, conduct survey cross sections, and perform technical background analyses to look at where a channel has been since the 1800s and map out its possible future.

“We can designate channel migration boundaries and place either a moderate or severe risk within those areas,” Bleifuhs says. “In a severe risk area, we have codes and regulations limiting the type of development.” For moderate channel migration zones, there are standards in terms of trying to build as far away from the channel as possible.

When communities keep elevation certificates and keep track of the mapping, they can receive points toward the CRS goal of facilitating accurate insurance ratings, Earl King explains.

Preparing and adopting comprehensive mitigation and floodplain management plans is another key factor of CRS. “We mandate plans,” Gates says. “If you have 10 or more NFIP repetitive losses–which are two or more losses of $1,000 each–you have to do a plan.” CRS offers ample points for communities that create a plan, whether they need to or not. Communities cannot get a Class 4 or higher rating without one.

Gates says one goal of CRS is for communities to have one plan that meets all standards of both FEMA’s pre-disaster mitigation program and CRS planning standards. “We have the Flood Mitigation Assistance Program for repetitive losses and CRS planning efforts, so now they are all one process,” he says. “Several communities have lost classes because they didn’t update their plan in time or have enough points in it to get to Class 4 or better. Planning is very key.”

Credits for acquiring or relocating flood-prone buildings are the highest in CRS, but they are also the hardest to come by. “Most communities are limited by funding,” Gates acknowledges. “Jefferson Parish in Louisiana has 5,000 repetitive loss structures–they’re not going to have a local program that can take care of that. They’ve mitigated a few hundred over the years. But they’ve had a lot of help from FEMA doing that. Through disasters, and without getting into Katrina, there’ll be lots of opportunity there.

“In the planning process, municipalities should list those structures, take care of them, and indicate they’ll take advantage of them whenever an opportunity arises,” Gates adds. “Pre-disaster mitigation programs helped a lot through providing grants to help relocate those structures.”

If there are 1,000 structures in a floodplain and a municipality has taken care of 100 of them, it receives 10% of the possible points. “Some communities are working on it quickly, others slowly,” Gates says. “We have a potential first Class 1 community that had 24 repetitive loss buildings and was able to take care of 22 of them, so they are getting an awful lot of points in that area.”

As critical to CRS as acquiring or relocating flood-prone buildings is preserving hazardous areas as open space, which is also crucial to avoiding future losses, Gates says. Controlling zoning and building codes is one way of preserving open floodplain space.

“If municipalities maintain certain areas and indicate they won’t build on them, that reduces flooding for the community, because there is a place for the water to go,” Earl King points out.

Open space in western communities often performs well, he says, adding that it’s vital, before development pressure starts, to hold those areas as open space for flood protection as well as to mitigate environmental impacts of development. However, Gates acknowledges that enacting and enforcing high regulatory standards for development is tough to do.

 “The easiest approach is to build to the base flood elevation, 1 to 3 feet. A lot of CRS communities have it at least at the 1-foot level, many at 2. To go higher is difficult, but we point out that because of stormwater management issues and the older FEMA maps we struggle to keep up to date, it’s a good idea to have a safety margin for new construction.”

He adds, “It’s critically important, if someone builds in an area, that communities tell them which areas to avoid and what they have to do in order to safely build a home to avoid the most hazards, including floods,” he says.

For those who have homes in hazard areas, he says, “They need to know if they build a small floodwall, shield, or berm around their house at X cost–or even keep leaves away from the storm drain–that while they wouldn’t prevent the 100-year flood, they would prevent nuisance floods.”

Maintaining drainage systems by cleaning channels and ditches is the core of most communities’ programs in preventing nuisance floods, Gates says. Illustrating the importance of that, he tells an anecdotal story of a California community where a major flood moved through on trash day, when everybody put their bags out on the streets. The weather event carried the bags into the inlet structures, clogging up some smaller culverts and causing flooding.

“The first 500 points of CRS is largely taken up by channel debris removal, cleanup and outreach projects, and keeping elevations,” Gates says.

Earl King adds that in addition to municipalities performing these actions, many communities can get credit by requiring that new developments maintain their own system.

Gates says CRS wants to encourage these actions in the most environmentally sensitive way possible and has made changes to accommodate special circumstances. “For some communities, that still means a backhoe, and in others, it means very gently removing woody debris or moving it from one side of the bridge to another,” he says.

Case in point: King County. Home to a salmon population, the county operates under the auspices of the Endangered Species Act. “We are not in a position of going into the channels and removing all the debris and dredging sediments or gravels to maintain capacity, so we’re leaving the rivers more or less in their natural state,” says Bleifuhs. “It’s been a two-year battle for us to get over that hump so CRS administrators would recognize our activities as being compliant.”

The Role of Stormwater Management
Stormwater management is a key part of CRS, Gates says. “CRS likes to work with communities that have identified problems in their past and work to take care of that through acquisition and relocation; the next part is trying to avoid future damages by regulatory practices. Stormwater fits right in there,” he says. “We offer hundreds of points for stormwater management programs, particularly since we know that a third of the NFIP losses are in zones outside the 100-year floodplain. Stormwater management helps mitigate all future development, and that’s the key to a large part of our program.”

Consultant Leslie Bond of LA Bond Associates in High Rolls, NM, is FEMA’s reviewer for the stormwater management credits. Bond, whose education is in hydrology and whose background is in floodplain management, has worked with CRS from its inception and believes CRS is the only incentive program to improve floodplain management in the country. For many other CRS activities, there are several specialists within a region that provide evaluation. However, “stormwater management is so complex and so varied across the country that to be fair to everyone and be consistent in rating, it was believed they should have a specialist to review it, and that’s the role I fill,” Bond says.

Bond says there are two approaches to earning credit for stormwater management. The first is through regulations whereby a community requires each new development to maintain predevelopment conditions for a particular design storm, which Bond notes has a positive effect on the increased runoff from new developments.

The second approach involves conducting basin-wide studies. “If you simply contain water on each development and release it at the pre-development peak flow rate, as you go downstream the peak flows will still increase because the duration of discharge from each of these small developments is longer,” Bond says. “If you do a watershed master plan, you account for that.”

Bond says exemplary stormwater management programs are common in western US communities where there has been ongoing work for a few decades, including a number of communities in California, Arizona, Nevada, Colorado, and Washington. Some Chicago-area counties also have “excellent” programs, Bond says.

“Where you have a county-wide agency, stormwater master planning seems to work better because those agencies can do watershed studies more easily than a community that only covers part of a watershed,” Bond notes. “It seems to be that counties have a taxing authority, a stormwater utility, or a flood control district tax, and they have the money to do these stormwater master plans, which are fairly expensive,” he says.

Bond also notes stormwater management activity is most abundant in high-growth areas, such as Florida. Earl King says Florida has the most CRS communities of any state: 200, representing nearly one-fifth of all communities involved in the program. But there are few communities in the state of Florida that perform stormwater management for the 100-year storm.

“There are special problems in Florida,” Bond notes. “There is little slope to drain the water away, so they approach flooding and stormwater differently than these fast-growing western communities. The water management districts created in Florida many years ago have used the 25-year flood standard for most of their designs, so as communities do something to complement the water management districts, they generally use the 25-year standard. In other parts of the country, stormwater management by the best communities is always the 100-year standard.”

King County gets a lot of credits for its stormwater control manual, one which Bleifuhs notes is “one of the most comprehensive manuals throughout the country.”

In Hilton Head Island, SC, CRS Coordinator Trudie Johnson teamed with City Engineer Scott Liggett to document for CRS a few programs in place, which included a ditch inspection program and stormwater regulations the town had enacted. The ditch inspection program encompasses 13 watersheds on the island, which Johnson and Liggett mapped out. Twice a year, they conduct inspections.

Johnson says that in 1994, the town encountered flooding from two simultaneous storms–one a 75-year storm, the other a 100-year storm–plus hurricanes and 12 inches of rain two weeks in a row. Much of the flooding was caused by drainage problems. As a result, 350 structures flooded.

The town hired a consulting firm to prepare a master plan for all of its drainage. An inventory was conducted of the town’s 13 watersheds, and all of the drainage areas were inventoried and prioritized for improvements. Some $20 million worth of work has been done since 1995.

“We have all open ditches, and in a lot of cases they are relatively shallow,” Johnson says. “My job has been to inspect to make sure those ditches, pipes, and other structures are maintained–that there is not a shopping cart blocking something, that pipe ends are not broken off and sinking, that there is no litter, cans, bottles, or debris.” Johnson says Hilton Head Island has written a protocol of how the town handles ditch maintenance.

Hilton Head Island also gets points for regulating development based on impervious and pervious coverage, for detention and retention design, and for public maintenance of stormwater facilities, Johnson says.

Top Performers
Four communities and their programs are standouts. On the top is Tulsa, one of the first cities to get involved in CRS when it began. The city received a Class 5 rating in 1992, attaining the highest rating in the country at that time. Today, Tulsa is the only community to have a Class 2 rating, again the highest in the country.

That rating resulted in a decrease in flood insurance premiums of 40% in the flood hazard area and 10% in the preferred risk zone. It’s estimated that the city is deriving an annual savings of $180,300 for the 1,945 Tulsa residents with flood insurance. 

Tulsa got involved in CRS to save its citizens money on flood insurance premiums, reduce flood losses, and promote awareness of flood insurance in general, says Stout. “Tulsa had the best program going as far as exceeding the minimum in NFIP standards at the time, and it would be beneficial to join the program.”

Tulsa has had a history of flooding, including a large flood in 1984 and one in 1986 that resulted in severe losses of property and loss of life. That gave Tulsa the impetus to move forward in CRS and other activities, Stout notes.

Some areas in which Tulsa has received many credits include its elevation certificate program, structural improvements, and floodplain analyses, which have reduced flooding levels.

Tulsa’s floodplain acquisition program began after the 1984 flood, which cost 14 lives and did $180 million in damage, Stout says, adding the program gained national publicity. “The city purchased and removed more than 300 homes from the floodplain after the 1984 flood,” he says. “After the 1986 Arkansas River flood, the city purchased 13 substantially damaged homes.”

Between 2002 and 2005, Tulsa acquired and cleared 35 buildings–including 15 repetitive loss structures–from the Special Flood Hazard Area and city regulatory floodplain. Stout says Tulsa has 8,603 properties in the regulatory floodplain, of which 2,613 are in the FEMA regulatory floodplain and 5,990 in Tulsa’s regulatory floodplain.
Repetitive loss property acquisitions is another area in which Tulsa has received many credits. Candidate structures are ranked according to policies developed by Tulsa, he adds. Criteria include depth of flooding and a favorable FEMA benefit/cost ratio. Priority has been given to single-family residential buildings. Participation is voluntary.

Flood insurance coverage is required to participate in the Flood Mitigation Assistance (FMA) program, Stout says, which provides funding for acquisition. Buildings without flood insurance coverage are purchased using Hazard Mitigation Grant Program (HMGP) funds. Both programs are administered through the Oklahoma Department of Emergency Management. The availability of a 25% local match of funds is confirmed and property owners are contacted to determine their interest in participation in the program. Then an acquisition application is put together and sent to the state for approval.

Tulsa is now moving toward attaining a Class 1 rating. “We have to get 50% of our properties in the floodplain to get flood insurance,” Stout says, adding that presently, the rate is 25%.

The second highest CRS-rated municipality in the United States–and the top-rated county–is King County, WA, with a Class 3 rating. The county contains a mix of urban and suburban development in the western part and mostly rural area in the eastern part. The Cascade Mountains abut the county’s eastern half, bringing runoff and drainage into the county’s lowlands. Additionally, six major river systems traverse the region.

“What causes our major flooding are these Pineapple Express weather systems that come up with a lot of warm air, moisture, and rain and what we call a “˜rain on snow’ event,” explains Bleifuhs. “We have accumulation of snow in the mountains and this Pineapple Express that comes up and slams us for a week or two causes all the rivers to rise.”

Although dams exist on several of the rivers, some were not designed for flood control but for Seattle’s water storage, so they don’t provide flood control per se but are managed for mutual benefits, Bleifuhs says. The Snoqualmie River system is one that does not have a dam, so all of the flooding that occurs from it is unmanaged, he says.

“Some of the highest damages come out of that river system, more than anywhere in Washington state,” Bleifuhs notes. “In fact, the city of Snoqualmie–which the river runs through–has the highest flood claims of any city in the state. It’s pretty significant.”

Bleifuhs points out that King County got involved in CRS during its inception in 1990 because it was already ahead of the curve on floodplain management. “It seemed like a natural fit to jump into the program and take our activities, programs, policies, projects, regulations, and codes and match them up against CRS programs to see how we did,” he says. “It turns out we ranked quite well.”

The cornerstone of King County’s program is long-established policies ensuring that no activity in the floodplain can result in an increase in the height, duration, or frequency of a flood event on neighboring parcels. Another code requires anyone bringing fill into a floodplain to excavate and remove the same amount from the floodplain to avoid an increase in material that would cause an increase in height, frequency, or duration of flood events, Bleifuhs says.

Like King County, Fort Collins, CO, prides itself on being proactive in floodplain management. The municipality also became involved in CRS in its early stages.

“We’ve had a stormwater utility since 1980, one of the first in the country,” notes Marsha Hilmes-Robinson, the town’s floodplain administrator. “CRS was a way to get credits for the activities we were already doing and provide a benefit to the citizens through the flood insurance discounts.”

Fort Collins is the only Class 4–rated community. The city has received credits for nearly every activity, including public outreach, flood warning systems, drainage system maintenance, and open space preservation.

Its flood warning system was installed with grant money after a major flood in 1997. The city now maintains it and has put in place a series of new operational procedures for dealing with response to alarms, notes Hilmes-Robinson. That includes working with the local fire department to coordinate their response to evacuations and public notifications.

Hilton Head Island also was one of the first CRS communities, filing its first application in 1991.

“It is a very good program for Hilton Head,” says Johnson. “We have a huge risk from flooding and had a lot of flood insurance policies–about 80% of the island is in a flood hazard zone–so to have deductions in flood insurance policies, even in the very begin

About the Author

Carol Brzozowski

Carol Brzozowski specializes in topics related to resource management and technology.