In an October 21 comment letter to the Federal Emergency Management Agency (FEMA) regarding its its proposed regulations and policies for implementing the Federal Flood Risk Management Standard (FFRMS), AMWA urged the agency to make clear in the final rule how the interpretation of the FFRMS will proceed if more than one agency is involved in providing project funds. To ensure consistency, FEMA’s policy proposal is to encourage early coordination among multiple federal agencies when they are jointly engaged in an action. However, the FFRMS states that agencies may apply one of three approaches to determining the extent of the floodplain and it is unclear how a final decision would be made to define a floodplain if multiple agencies are involved in funding a project.
AMWA also expressed support for FEMA’s decision to use more precise language when describing potential flood occurrences. For instance, a 100-year flood would be described as a 1 percent annual chance flood. The change will, over time, improve the public’s understanding about these events.