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Local Hazard Mitigation Plan and Community Rating System Crosswalk Starter Kit

FEMA has two major hazard mitigation planning programs: local multi-hazard mitigation planning, and floodplain management planning under the Community Rating System (CRS). In most cases, doing a thorough job of including the protection of natural floodplain functions and floodplain species assessments in mitigation planning will often lead to more credit under Activity 510 of the CRS (specifically Element 512.a - Floodplain Management Planning.

CRS Points Available per Step

CRS Planning Step Maximum CRS Points Average Points Earned
1. Organize to prepare the plan 15 10
2. Involve the public 120 34
3. Coordinate 35 10
4. Assess the hazard 35 25
5. Assess the problem 52 29
6. Set goals 2 2
7. Review possible activities  35 20
8. Draft an action plan 60 42
9. Adopt the plan  2 2
10. Implement, evaluate and revise 26 5
Point Total 382 171

As of May 2018, 99% of CRS communities also have a local hazard mitigation plan. However, the vast majority of CRS communities have not been able to maximize credits under Activity 510 (see Table 1). This handout is meant to help communities integrate mitigation planning and CRS planning. This will help them to produce more effective local flood mitigation actions and meet the criteria of both FEMA programs more efficiently.

This handout summarizes the similarities between local hazard mitigation plan elements and the CRS steps and highlights key differences that are commonly overlooked.

(See FEMA’s Mitigation Planning and the Community Rating System Key Topics Bulletin for more detailed information).

There are many similarities between mitigation planning and CRS planning. Mitigation planners should be aware of some special criteria for the CRS credits. This handout is to help those preparing a local hazard mitigation plan who wish to include elements that will also earn CRS credits. This handout takes each local hazard mitigation plan element and:

  • Provides the corresponding CRS step.
  • Summarizes the CRS step.
  • Calls out prerequisites and key differences between CRS and local hazard mitigation plan review criteria.
  • Explains how to maximize CRS points.
  • Highlights commonly missed elements (in callout boxes throughout this fact sheet).

There is one overarching difference between local hazard mitigation plan and CRS requirements: local hazard mitigation plan elements are either met or not met, whereas CRS steps are points based. Many CRS steps have minimum criteria, but a community earns more points for additional activities[1]. While CRS requirements are points-based, the planning process must at least address all 10 CRS steps of Activity 510. Skipping one of the CRS steps could result in no CRS credit or credits capped at 50 points.

CRS Step(1) Local Hazard Mitigation Planning Element(2) Crosswalk Details Commonly Missed CRS Elements
Step 1.
Organize to prepare the plan
A1. Document the planning process

Prerequisites:

The CRS requires a Floodplain Management Plan (FMP) committee.

Key Differences:

The FMP committee can be the local hazard mitigation planning committee. It can also be a separate FMP committee that focuses on flooding.

The FMP committee must meet at least five times (at key steps in the planning process - Steps 4, 5, 6, 7 and 8).

For multi-jurisdictional plans, each community that wants to earn CRS points must have two staff representatives on the FMP committee.

At least half of the representatives must attend all meetings of the FMP committee.

Maximize Points (3):

Involve staff from multiple departments; include the community departments that implement or have expertise in activities of the plan. One point is given for each office represented; full credit is given for staff representing all six categories of CRS flood mitigation activities (see Table 2 below).

Formally establish the planning process through the community’s governing body.

A typical local hazard mitigation plan planning committee is different from an FMP committee. CRS requirements are more specific; you cannot go back and "fix" this at the end..

Step 2.
Involve the public
A3. Public involvement during the planning process

Prerequisites:

The CRS requires a Public Planning Committee. This can also be the local hazard mitigation plan stakeholder group. Key Differences:

A local hazard mitigation plan requires the opportunity for stakeholders to participate; CRS requires active stakeholder/public participation

Maximize Points

Full credit is given if at least half the committee members are from outside the local government.

Hold at least one public information meeting in the affected area(s) within the first 2 months of the planning process. This is separate from the planning committee meetings.

Hold at least one public meeting at least 2 weeks before submitting the plan. Use the meeting to get input on the recommended plan.

- Five points are given for each additional public information activity that explains the planning process and encourages input.

CRS's definition of stakeholder/public involvement is more structured than what the local mitigation plan guidance describes

Step 3(a).

Review existing studies, reports and technical information

A4. Review and incorporation of existing plans, studies, reports and technical information

Prerequisites:

Step 3(a) is basically the same as sub-element A4:

  -  Review existing studies, reports and technical information. Review the community's needs, goals and plans for the area.

 
Step 3(b).

Coordinate with agencies and organizations

A2. An opportunity for neighboring communities and local and regional agencies to be involved

Key Differences:

Step 3(b) is similar to sub-element A2, but it requires more than providing a chance to get involved.

Maximize Points:

Work with agencies and organizations outside the community's governmental structure to get their hazard data and ask for their input and participation in the process.

Aside from contacting the various agencies and organizations outside the community's government structure, planning staff must document the contacts made and their responses.
Step 4. Assess the hazard B1. Hazard profile

Prerequisites:

The flood hazard assessment must include the sources, frequencies, extent and causes of flooding. Flood hazard areas that require assessment include:

  - The Special Flood Hazard Area shown on the Flood Insurance Rate Map (FIRM).

  - All repetitive loss areas if the community is a Category B or C (CRS communities should have already prepared repetitive loss area maps).

  - Areas not mapped on the FIRM that have flooded in the past (flood insurance claims can help with this).

  - Other surface flooding identified in other studies.

Key Differences:

Most local hazard mitigation plans meet the minimum requirement. Giving more details is an opportunity to get more points.

Maximize Points:

Include the following: discussion of less frequent flooding; areas likely to flood and potentially become worse in the future; and areas of past flooding and other natural hazards.

 
Step 5. Assess the problem B2. Hazard impact, vulnerability, and NFIP assessment

Prerequisites:

A summary of the jurisdiction's vulnerability to each hazard and the impact (the base criteria are basically the same as those for sub-element B2).

Repetitive Loss (RL) communities must:

Include their RL areas.

Describe the causes of repetitive flooding.

Send an annual mailer with information on ways to protect properties from repetitive flooding.

Key Differences:

Most local hazard mitigation plans meet the minimum requirement. Giving more detail is a way to get more points.

Maximize Points:

Provide further details beyond the overall summary:

  - The impact of all flood-related hazards on various community attributes (including flood warning and evacuation systems; public health; critical facilities and infrastructure; local economy; and buildings).

  - Historical damage to buildings.

  - The area's natural floodplain functions.

  - Future development and redevelopment.

  -  flooding conditions due to climate change.

For a multi-jurisdictional plan, you must describe each item for each community.

 
Step 6. Set goals C3. Mitigation goals

Prerequisites:

This is basically the same as sub-element C3: set mitigation goals.

Goals can be broad, but must address all flood-related problems in Step 5.

 
Step 7. Review possible activities

C1. Capability assessment

C2. NFIP participation and compliance

C4. Mitigation strategy

Prerequisites:

Review and consider preventive activities.

The plan needs to discuss what was examined and why certain actions were recommended.

Key Differences:

When describing your mitigation strategy, you MUST describe the actions you considered, the actions you chose, and your reasoning for deciding why each activity was appropriate or not for the community and its flood problems.

Mitigation planning and the CRS have lists of six types of mitigation actions/activities. These lists differ.

Maximize Points:

Review whether the community’s floodplain management regulatory standards are sufficient for current and future conditions, as discussed under CRS Steps 4 and 5.

Review if activities protect natural and beneficial floodplain functions. More points are given for reviewing multiple categories of flood mitigation measures. Full credit is given if you identify and discuss measures from all six flood mitigation categories

Missing CRS Step 7 is the most common reason that FEMA-approved mitigation plans are capped at 50 CRS points.

Many hazard mitigation plans omit this discussion. The planning staff may have done such a review, but for CRS credit, the plan document must describe the review. Omitting the review pieces of your process results in no credit for CRS Step 7.

Step 8. Draft an action plan C5. Mitigation prioritization

Prerequisites:

There must be an action item for each goal listed in CRS Step 6.

Actions must be prioritized.

Key Differences:

CRS steps are more specific than the local hazard mitigation plan requirements.

Maximize Points:

Full credit is given for an action plan with actions in five of the six flood mitigation categories.

More credit is offered for including policies and procedures for post-disaster redevelopment and mitigation in the action plan, as well as for action items that mitigate the effects of other natural hazards.

Mitigation actions need to be tied to goals. Every goal needs at least one action associated to it.
Step 9. Adopt the plan

F1. Plan adoption

F2. Multi-jurisdictional plans – plan adoption by each participant

Prerequisites:

Adoption must be in the form of a resolution or other formal document. It must be voted on by the community’s governing body.

  - A multi-jurisdictional plan must be adopted by the governing body of each community seeking CRS or multi-hazard mitigation plan credit points.

Key Differences:

Most local hazard mitigation plans are adopted via formal documentation. Other forms of adoption are allowed for local hazard mitigation plans.

Maximize Points:

Communities are encouraged to send the draft plan to their Insurance Services Office, Inc. (ISO)/CRS specialist for a technical review and preliminary scoring. They should also send it to the state emergency management agency and FEMA for a courtesy review.
 
Step 10.

Implement, evaluate, and revise

D1. Continued public participation

D2. Plan monitoring, evaluation, and update

D3. Integration of the local hazard mitigation plan

Prerequisites:

The plan must describe how, when and by whom the plan will be monitored, evaluated and revised.

Progress toward plan implementation must be evaluated at least every year.

The procedures for doing this must be explained in the plan document. The evaluation report must be made available to the media and the public.

An evaluation report must be prepared and distributed to the governing body, the media and the public. It must be submitted to the ISO with the community’s recertification package.

The plan must be updated every 5 years.

The community must submit a copy of its plan update at least every 5 years.

Key Differences:

A local hazard mitigation plan requires you to discuss the evaluation process; the CRS requires proof that evaluation occurs each year.

Maximize Points:

To encourage continued public involvement, more points are given for having the evaluation report prepared by the CRS Step 2(a) planning committee.

Once the plan is adopted, more points are given for more frequent committee meetings during the year. These meetings are to review progress and recommend revisions.

Multi-hazard mitigation plans must include a process for how the community will integrate the requirements of the plan in other community plans. These other plans can include capital improvement, zoning ordinance, and the general/comprehensive plan.

The plan must include proof that evaluation occurred each year.

1. The 10 CRS steps are detailed in Activity 510, Section 512.a, Floodplain Management Planning (FMP) at https://crsresources.org/manual/.
2. Planning elements are per the Local Mitigation Planning Policy Guide and its Plan Review Tool.
3. Table 1 illustrates the CRS Element 512.a points available, and the typical points earned by a local hazard mitigation plan.

Note that specific requirements for other CRS steps dovetail with those of Element E (Plan Update) and sub-elements E1 and E2. Adequately addressing CRS Steps 4, 5, 6, 7 and 8 will meet the requirements of E1 and E2. The connections with the plan update requirements are described below:

CRS Step Local Hazard Mitigation Planning Element Crosswalk Details

Step 4. Assess the hazard

Step 5. Assess the problem

E1. Changes in development

Prerequisites: None

With a plan update, hazard and problem assessments must be reviewed and brought up to date. They must account for:

  - Completed mitigation projects.

  - Increased development in the floodplain or watershed

Step 6. Set goals

Step 7. Review possible activities

Step 8. Draft an action plan

E2. Mitigation strategy progress and changes in priorities

Prerequisites: None

With a plan update, the original plan's goals must be reviewed to determine if they are still appropriate (given the revisions to Steps 4 and 5).

With a plan update, each activity recommended by the previous plan must be discussed, along with the status of implementation.

With a plan update, the action plan must be revised to account for projects that have been completed, dropped or changed. It must also account for changes in the hazard and problem assessments.