asfpm annual conference capitalizing on your authority for true mitigation mark eberlein fema region...

ASFPM Annual Conference

Capitalizing on Your Authority for True Mitigation

Mark EberleinFEMA Region 10Regional Environmental Officer

ASFPM Annual Conference 2011 2

Mitigation Purpose and Intent

Authority

Mission Statement

What are we about?

ASFPM Annual Conference 2011 3

How do we Mitigate?

AvoidMinimizeRectifyCompensateE

ffect

iven

ess D

ifficulty

ASFPM Annual Conference 2011 4

Executive Order 11988 Floodplain Management

Intent

Section 2(a)(2)

Section 2(c)

ASFPM Annual Conference 2011 5

Water Resources Council Guidelines for Floodplain Management

8 step processStep 3 AvoidanceStep 6 Re-evaluation

ASFPM Annual Conference 2011 6

44 CFR Part 9 Floodplain Management and Protection of Wetlands

Part 9.2 Policy Part 9.6 Decision Making

Process Part 9.9 Analysis and

reevaluation of practicable alternatives

Part 9.16 Guidance for Applicants

Part 9.17 Instructions to applicants

ASFPM Annual Conference 2011 7

What is “practicable?”

Part 9.4 Definitions

Capable of being done within existing constraints- Depends upon the situation- Includes consideration of pertinent

factors- Environment- Cost- technology

ASFPM Annual Conference 2011 8

Implementing within HMA

HMA Planning

HMA Projects

ASFPM Annual Conference 2011 9

Implementing within HMA PLanning

Best of the best (Enhanced Plans)

FloridaWisconsin IowaCaliforniaWashington

ASFPM Annual Conference 2011 10

Implementing within HMA Planning

Step 3 Considered?

Step 3 given a Hard look?

Step 3 action or just words

ASFPM Annual Conference 2011 11

Implementing within HMA Planning

Is FEMA Planning Guidance meeting our obligations under Part 9?

Are our planning efforts having the results we want?

Can we do a better job?

ASFPM Annual Conference 2011 12

HMA Project implementation

Results of HMA fundingData for Acquisitions/ all

HMA projectsData for Elevations/ all

HMA projects

ASFPM Annual Conference 2011 13

Elevations for selected states

Report on Elevation Projects in Select States by FY   

State Program FY Approved Net Project Amount Properties Elevated

California 1994-2011 $47,601,929.10 $61,735,904.10 1,087

Florida 1995 - 2010 $22,634,161.02 $69,628,017.07 762

Iowa 1993 - 2007 $10,359,459.00 $17,794,485.60 25

Washington 1996 - 2011 $31,849,898.68 $37,538,011.50 456

Wisconsin 1993 - 2010 $2,849,162.82 $3,112,988.97 30

ASFPM Annual Conference 2011 14

HMA Project implementation

Hard LookAre applicants meeting

our instructions?Does our guidance reflect

the hard look?Is the intent being fully

met?

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What are we do to?

Authority

Policy

Guidance

Actions

ASFPM Annual Conference 2011 16

What are we do to?

Risk PlanningPlanning documents should

reflect the hard look for avoidanceVigorous analysis for continued

occupancy needs to be addressedRequire prioritizations for

avoidanceRequire justifications for not

avoiding

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What are we do to?

HMA ProjectsFund only Acquisition

projects unless demonstrated otherwise on practicability

Rigorous review of project criteria [Part 206.434(c)(3)] demonstrated at application, not at EHP review.

ASFPM Annual Conference 2011 18

What are we do to?

Avoid

Minimize

Rectify

CompensateEffe

ctiv

enes

s Difficulty

Upfront Effort

Questions?

Mark EberleinFEMA Region 10Regional Environmental Officer