Matt’s Blueprint for Largo Reaching a FEMA CRS Class 2 Rating

To create a blueprint for the City of Largo to move to a FEMA CRS rating of Class 2 via floodplain management, the city would need to significantly enhance its efforts across the four main CRS activity categories: Public Information, Mapping and Regulation, Flood Damage Reduction, and Flood Preparedness. 

A Class 2 rating offers a 40% premium discount on flood insurance for policyholders. This goal has already been achieved by Unincorporated Pinellas County.

Phase 1: Assessment and Planning (Ongoing)

  • Comprehensive Review of Current CRS Credits: 

    • Conduct a detailed assessment of all current activities and the associated credit points Largo currently receives under the CRS program. 

    • This requires a thorough review of the **CRS Coordinator's Manual** and its **2021 Addendum**, which explains the criteria and credit points for all CRS elements. 

    • This assessment will identify strengths and areas needing improvement.

  • Targeted Gap Analysis: 

    • Identify the specific activities and credit point thresholds needed to achieve a Class 2 rating. 

    • Resources designed specifically for CRS communities, including the Coordinator's Manual.

  • Establish a Dedicated CRS Enhancement Team: 

    • Assign a dedicated team or expand the responsibilities of existing floodplain management staff to focus specifically on CRS enhancement activities. 

    • This team should work closely with Pinellas County's Flood Risk and Mitigation Public Information Working Group (FRMPIWG) and consider utilizing vendors like CRS Max for guidance.

  • Develop a Detailed CRS Enhancement Plan:

    • Outline specific, measurable, achievable, relevant, and time-bound (SMART) goals and actions within each of the four CRS categories to increase the city's credit points. 

    • This plan should address the impact of the recent amendment to Largo's Comprehensive Development Code (CDC) to repeal cumulative substantial improvement determinations. 

      • This change, while intended to mitigate challenges for homeowners making storm-related repairs under the FEMA 50% Rule, might present a setback in CRS points. 

    • The plan should identify alternative or enhanced activities to compensate for potential point losses. 

    • It is important to note that the LMS has new state requirements, including that communities look at Severe Repetitive Loss (SRL) areas and repetitive loss properties and have a substantial improvement/substantial damage plan in place.

    • Pinellas County has one that can be reviewed and potentially adapted.

Phase 2: Enhancing CRS Activities

Category 1: Public Information (PI)

  • Expand Outreach Initiatives:

    • Build upon existing efforts like the Flood Guide and real estate flood disclosure program.

    • Implement a wider range of activities such as developing and disseminating targeted flood risk information through various channels, including social media (#floodplainfriday), podcasts, utility bill inserts, library materials, and the city website. 

    • Ensure all materials are ADA compliant. Conduct more frequent community workshops and presentations on flood risk, flood insurance, and mitigation measures. Implement DIY high water marking programs. 

    • Collaborate with local media to increase awareness (e.g., Tampa Bay Newspaper inserts). Ensure consistent messaging with Pinellas County's Program for Public Information (PPI). 

    • Actively participate in the FRMPIWG and implement relevant projects from the Outreach Project (OP) Matrix. 

    • Updates to outreach materials like the New Homeowner Brochure should be considered and consistent messaging developed.

    • Leverage the FRP Messages Toolkit, which includes messages categorized by event and is being made searchable.

  • Enhance Real Estate Disclosure:

    • Ensure robust real estate flood disclosure practices are in place, potentially including information about past flood damage and unpermitted work. 

    • Real estate agents should be a target audience for information about the Pinellas County Flood Map Service. Training for real estate agents on flood disclosure and information is available.

  • Promote Flood Insurance: 

    • Actively encourage residents to purchase and maintain flood insurance. 

    • Emphasize the benefits and potential cost savings through the CRS program discounts. 

    • Disseminate information about Risk Rating 2.0 and the importance of understanding individual policy details. 

    • Pinellas County uses Flood Insurance Advocates as stakeholders to assist residents. Messaging about Risk Rating 2.0 should be reviewed and potentially updated. 

    • Information about the transferability of NFIP policies should be added to insurance messaging. 

    • Encourage homeowners to assess their flood insurance coverage every 5 years. Consider adding messages about the percentage of homeowners without insurance.

  • Map Information Service (Activity 320):

    • Utilize and promote the Pinellas County Flood Map Service, which provides access to FEMA Flood Insurance Rate Map (FIRM) information and links to the FEMA Map Service Center (MSC). 

    • The MSC provides access to the National Flood Hazard Layer (NFHL), FIRMs, and FIRMettes. 

    • The county's service improves dissemination of flood risk data and available measures for homeowners.

Category 2: Mapping and Regulation (MR)

  • Utilize Enhanced Flood Hazard Data:

    • Go beyond FEMA FIRMs by fully integrating Pinellas County's enhanced flood maps that incorporate tidal, rainfall, and storm surge data. 

    • Make this information easily accessible to residents through online tools. 

    • Clarify that flood insurance is based on FEMA maps, but local development decisions can and should consider both FEMA and county maps, especially as FEMA maps may be based on older data.

  • Strengthen Floodplain Management Regulations:

    • Consider adopting more restrictive floodplain management regulations than the NFIP minimums, where feasible and beneficial. 

    • This could include: increasing freeboard requirements above the Base Flood Elevation (BFE), as a Class 8 rating requires at least a 1-foot freeboard for new construction or substantially improved or reconstructed buildings in SFHAs with BFEs.

    • Regulating development in areas subject to localized flooding not identified on FIRMs.

    • Implementing stricter regulations for development in repetitive loss areas. Utilize model ordinances as reference.

  • Track and Maintain Comprehensive Records:

    • Ensure meticulous record-keeping of all floodplain management activities.

    • This includes substantial damage determinations, permits, and elevation certificates. 

    • Maintain and make flood hazard maps, including superseded versions, readily available. 

    • Use the Pinellas County database to look up Elevation Certificates. A 2023 edition of the Elevation Certificate is available.

  • Review and Update Floodplain Ordinance Regularly:

    • Ensure the city's floodplain ordinance is consistent with the NFIP and incorporates best practices. 

    • The recent amendments to Largo's CDC to remove cumulative SI determinations, clarify requirements for elevation of manufactured homes, and amend definitions should continue to be carefully reviewed for their impact on CRS points and further updates considered as needed.

Category 3: Flood Damage Reduction (FDR)

  • Implement Structural and Non-Structural Mitigation Projects:

    • Develop and implement projects that reduce flood risk and damage. 

    • This includes acquiring and demolishing or relocating flood-prone structures, especially Severe Repetitive Loss (SRL) properties. 

    • Elevating flood-prone residential and non-residential buildings. 

    • Actively promote and assist residents in applying for hazard mitigation grants for elevation. 

    • Protecting and restoring natural floodplain functions. 

    • Implementing stormwater management improvements, exploring opportunities for regional stormwater facilities. 

    • Promoting low-impact development (LID) practices. 

      • Note CRS elements for structural projects include retrofitted buildings and structural flood control & drainage projects. 

    • Specific drainage system maintenance elements include

      • Channel Debris Removal (CDR)

      • Problem Site Maintenance (PSM)

      • Capital Improvements Program (CIP)

      • Storage Basin Maintenance (SBM).

  • Develop a Comprehensive Drainage System Management Plan:

    • Implement a proactive plan for maintaining and improving the city's drainage system to reduce localized flooding.

  • Promote Property Protection Measures:

    • Educate residents on property protection measures they can take, such as dry floodproofing, wet floodproofing, and installing backflow valves. FEMA provides guidance on dry floodproofing for non-residential structures.

  • Severe Repetitive Loss (SRL) Properties:

    • As required by state law for the LMS, develop a specific Substantial Improvement/Substantial Damage plan for SRL areas.

    • Information on procedures unique to servicing policies for SRL properties, including notification and underwriting requirements and processes for correcting SRL status, are detailed in the NFIP Flood Insurance Manual.

  • Floodplain Species Assessment and Plan:

    • Explore the potential for credit under Activity 510 for developing a floodplain species assessment and a floodplain species plan.

Category 4: Flood Preparedness (FP)

  • Enhance Flood Warning and Response: 

    • Review and update flood warning systems and emergency response plans. 

    • Ensure effective communication of flood warnings to residents through various channels like Alert Pinellas. 

    • Note CRS elements for warning and response include Flood Threat Recognition System (FTR), Emergency Warning Dissemination (EWD), Flood Response Operations Plan (FRO), and Critical Facilities Planning (CFP). Pinellas County has revised their Flood Warning and Response Plan.

  • Promote Evacuation Planning:

    • Educate residents about evacuation zones and routes.

    • Coordinate evacuation procedures for vulnerable populations, such as residents of mobile home parks.

    • Participate in severe weather preparedness initiatives like the Great Tornado Drill. 

    • Update the Hurricane Guide.

  • Strengthen Post-Flood Recovery Planning:

    • Develop and refine post-flood recovery procedures, including rapid damage assessment, permit processing, and communication with residents.

    • The city's experience with Hurricanes Helene and Milton provides valuable lessons. 

    • Streamline the substantial damage assessment process. 

  • FEMA has two options for substantial damage determinations: 

    • Proactive inspections or waiting for permit applications. Ensure adequate staffing for reviews and inspections.

    • Require permits for all repairs beyond temporary muck-out, roof tarping, or window blocking, even minor ones, as this is a point of conflict but required for substantial damage documentation. 

    • Prioritize issuing repair permits for specific project types. 

    • Be prepared for high volume of both electronic and paper applications.

  • Substantial Damage (SD) / Substantial Improvement (SI) Process:

    • When reviewing permits, ensure substantial damage documentation, including invoices and estimates, is submitted. 

    • The total cost of repair must be considered, not just the cost of the permit being issued.

    • This includes all work, volunteer labor, owner-builder work, donated materials, and invoices from contractors.

    • Anything attached to the structure (e.g., painting, faucets, electric, doors, windows, roof, foundation) is included in the cost.

    • Ancillary structures like sheds, seawalls, and docks, and plugin appliances do not count.

    • A consistent methodology must be used for calculating market value of repairs and labor.

    • Recommended sources include RS Means, online websites (HomeWise, HomeGuide), or Bureau of Labor Statistics data for labor costs.

    • The city is working with the county and other cities to ensure consistency in the values used.

    • The cost to return the home to its pre-storm state is determined. For contractor estimates, a 10% contingency and 20% profit may be included.

    • Utilize the Substantial Improvement/Substantial Damage (SISD) packet (formerly known as the FEMA packet). 

    • This packet requires an itemization and breakdown of costs for the project. 

    • If the approved SISD package indicates damage is less than 50% of the structure's value (based on FEMA wind loss mitigation letter, property appraiser website, or private appraisal), permits can be issued without waiting for a separate damage assessment letter.

    • Communities will be audited by FEMA, and they will have to answer for decisions regarding substantial damage determinations.

    • Communicate requirements clearly to residents, including the need for SISD packets and substantial damage rules. 

    • Provide clear guidance on permit applications, including cost breakdowns.

    • Offer assistance to residents with the permitting process. 

    • Be prepared to address conflicting information between building codes, floodplain ordinances, and NFIP requirements. 

    • If residents disagree with the substantial damage determination, an appeals process is available. FEMA provides substantial damage estimation tools and desk references.

Phase 3: Implementation and Verification

  • Implement the CRS Enhancement Plan:

    • Execute the identified actions within each CRS category.

  • Document All Activities:

    • Maintain thorough documentation of all CRS-related activities, including dates, participation numbers, materials used, and outcomes.

    • This documentation is crucial for the CRS recertification process. 

    • Digital documentation is encouraged to reduce paper files. 

    • CRS checklists are available to help assemble needed documentation. 

    • The ISO/CRS Specialist must collect materials on credited activities.

  • Regular Monitoring and Evaluation:

    • Continuously monitor the progress of CRS enhancement activities and evaluate their effectiveness in increasing credit points. 

    • Make adjustments to the plan as needed.

  • Annual Reporting: 

    • Ensure timely and accurate submission of the CRS annual recertification report to FEMA. 

    • Municipalities are also required to complete Annual Updates for the PPI and Repetitive Loss Annual Analysis (RLAA).

  • Seek Technical Assistance:

    • Leverage the expertise of Pinellas County staff, FEMA, and CRS experts throughout the process.

    • The ISO/CRS Specialist is a valuable source of information and assists communities.

    • Communities should prepare for a cycle verification visit every five years with the ISO/CRS Specialist to determine their CRS class.

    • A modification review can be requested at any time, especially if new activities could result in an improved class.

  • Verification Process:

    • The ISO/CRS Specialist verifies that class and activity prerequisites are met, calculates points, and processes the community file for FEMA's decision.Technical reviews may occur.

    • A draft verification report is sent to the community, subject to FEMA approval.

    • Information is given to FEMA twice per year. FEMA reviews the recommendations and sends the official notice of the verified CRS classification and the final report.

  • Reconsideration:

    • If the community believes something was missed or misinterpreted during the verification visit, it may request a reconsideration of its CRS classification by submitting a request to the FEMA Regional Office.

  • Using New Flood Data Post-Disaster:

    • If the community experiences flooding when new FEMA flood data (FIS) is near completion, adopting and enforcing this new data (if showing higher BFEs) for substantial damage compliance can help minimize future losses and potentially lower flood insurance premiums.

    • If the new BFEs are lower, they cannot be used for substantial damage compliance until the new FIRM is effective.

    • The ISO/CRS Specialist can provide specific advice on integrating new FEMA data.

  • Engage the Community:

    • Keep residents informed about the city's efforts to improve its CRS rating and the resulting benefits in terms of flood insurance premium discounts.

    • Address concerns and provide clear explanations about floodplain management regulations.

By diligently pursuing these actions across all four CRS categories, the City of Largo can strategically work towards achieving a Class 2 CRS rating, providing significant flood insurance premium discounts to its residents in Special Flood Hazard Areas and further enhancing community resilience. 

It is important to note that the removal of the cumulative substantial improvement determination might present a setback in CRS points, requiring a particularly strong focus on excelling in other credit-earning activities. Continuous engagement with FEMA and adherence to NFIP requirements are essential throughout this journey.