Experiences Gained: Getting Started in the CRS Program
Flood insurance premiums are expected to skyrocket as the frequency and severity of flooding events across the nation continue to rise. Although communities can’t control rising rates, county administrators can be proactive by enrolling their counties in the National Flood Insurance Program’s (NFIP) Community Rating System (CRS) – a program that reduces flood insurance premiums for communities who exceed NFIP’s minimum requirements.
The process of enrolling in the CRS can be daunting, especially for small communities, which often struggle to marshal the resources and resolve to implement the system. While the process of applying and the activities taken to earn CRS credit vary from county to county, IBTS identified several measures that can be taken prior to and during the first stages implementing the CRS program.
What is the CRS?
The CRS, which uses a point-based system to rank communities on a scale from 10-1, offers insurance discounts that increase incrementally as communities improve their ratings by implementing appropriate measures from an extensive list of approved mitigation activities. Communities can earn CRS points for 19 different activities, which are organized into four categories: public information, mapping and regulations, flood damage reduction, and warning and response. Learn more about these activities and how to improve CRS ratings here [link to improving your CRS score article].
Localities have been successful enrolling in the program before a flooding event to minimize damage from future floods, or after a flood as the locality rebuilds and improves existing floodplain management plans. Regardless of when a county decides to enroll in the CRS, getting started in the program presents a common set of challenges for small communities, including the requirements for sound floodplain management and having documentation in place.
Applying for the CRS
Many localities have already implemented CRS creditable activities, but are not reaping the benefits that come with the program due to a time- and detail-intensive application process. Binghamton, N.Y., a city of 47,000 located at the confluence of the Susquehanna and Chenango rivers, for example, had implemented several floodplain improvement measures after record-level rains caused flooding in 2006 and again in 2011, toppling the area’s extensive levee system and causing over $1 billion in damages. Yet they didn’t apply for the CRS until 2016, only then aligning their efforts with the CRS to take advantage of the CRS’ cost-saving benefits.
The CRS application process consists of two main components: sending FEMA a letter of interest on behalf of the community, and submitting documentation to the state Insurance Services Office (ISO) demonstrating that the community is implementing activities that warrant at least 500 points, or a CRS rating of 9. The second aspect of the application process is usually more difficult for small localities – even if they’ve already taken measures that would be creditable under the CRS, documenting them to CRS standards can be challenging.
“It somewhat depends on what the community already has in place, because they have to match it with fitting into the CRS,” says Marsha Hilmes-Robinson, CRS Committee Chair for the Colorado Association of Stormwater & Floodplain Managers (CASFM) and Floodplain Administrator and CRS Coordinator for the city of Fort Collins, Colo. Fort Collins is one of only five communities in the nation to receive a Class 2 rating or higher.
Examples of common activities that have already been taken by localities and can be counted towards the CRS include water quality, drainage system management requirements, public outreach and local higher standards.
Binghamton, for example, was able to draw credit from mitigation efforts they had taken in the years after their flooding events. One of their major credit-bearing efforts was a $2.7 million FEMA grant to remove 23 blighted homes in the floodplain and restore the area as open space – an eligible CRS activity worthy of up to 1,900 points. Tom Costello, Binghamton’s Supervisor of Building Construction, Zoning & Code Enforcement, notes that securing funding from external sources, like FEMA, is a key success strategy for communities with limited resources trying to complete projects that will qualify them for the CRS.
Furthermore, FEMA developed updated preliminary floodplain maps for the county after the 2006 flood, placing an additional 6,190 properties in the Special Flood Hazard Area (SFHA). The CRS mapping activity awards points to communities who place more properties in the SFHA, giving Binghamton another source of points prior to the application process.
Navigating the First Steps
Compile a CRS Team
The makeup of your CRS team will vary depending on the community and its capacity to take on the demands of the CRS. One of the prerequisites for participation in the program is appointing a CRS Coordinator, the person designated to be the official point of contact between the community and the program staff of the CRS. The county or city manager typically names a staff member from the Public Works Department to the position of CRS coordinator.
In Binghamton, the CRS team – known as the Floodplain Administration Planning Commission – is headed by the deputy mayor and includes the Mayor’s office, and the engineering, public works, planning and code enforcement departments. The commission meets monthly and is coordinated through the Planning Department. Although the approach to organizing and convening a CRS committee will differ by locality, Binghamton’s structure is typical of a small city or county.
Take a Customized Approach
The intention of the CRS program is that each participating locality will develop a floodplain management strategy matching its unique needs and capabilities. FEMA actively discourages a one-size-fits-all approach, as well as the concept of “low-hanging fruit” – the activities easiest and most common to get point credit.
To simplify the process of identifying a county’s most pressing needs, Costello recommends developing templates to provide structure and identify community-specific improvements. CRS Coordinators can take the lead in developing a template that identifies and prioritizes CRS creditable activities most relevant to the county.
“Hand me a template – ten things you can do, with instructions and structure,” says Costello. “Get the low-hanging fruit items first and then sequence them according to the others. Identify the logjam links – they’re the big, important ones that are requirements for others.”
Develop a Structure for Persistent Recordkeeping and Repetitive Tasks
One of the largest barriers for communities starting the CRS process is the lack of resources and structure in place to record CRS activities and requirements in the format mandated by FEMA. Many localities struggle to keep adequate documentation of elevation certificates (ECs), which must be kept on-record and maintained to be accurate under the CRS standards, and are a prerequisite for the program.
“In our ISO audit, we talked about CRS and found that we do a lot of the activities,” explains Costello. “We have elevation certificates on file, but not in a systematic programmatic file that is suited for regular updates.”
In addition to elevation certificates, initiatives taken in the past to improve floodplain management plans can get lost in the transition between administrations if no structure is in place to implement the project under a new program. “Without structure in place and dedicated job descriptions, the initiative gets,” Costello says.
Supplement Resources with External Consulting Firms
Communities that want to enroll in the CRS, but are intimidated by the initial processes of getting started in the program, should consider employing experienced professionals to help them navigate the process.
“There’s been an explosion of consulting firms in recent years,” says Hilmes-Robinson. “The documentation is so cumbersome and burdensome that some communities are just handing it off to consultants.”
Although consultants can be costly – reaching upwards of $50,000 – in many cases the long-term benefits make the investment cost-effective. Consultants typically take over the GIS and documentation tasks, working closely with the locality through the first or second year of the program.
“The best time to get involved is when they [the locality] are getting ready for the ISO meeting,” Holmes-Robinson says. She then recommends that the consultant attend meeting to ensure that the ISO reviewer focuses on developing a floodplain management plan that best suites the locality’s needs, instead of focusing on the easiest, most commonly completed CRS measures.
For localities that don’t have the funds to hire a consultant, user groups can be a great resource. “User groups share how communities have fulfilled the documentation requirements,” says Hilmes-Robinson. “If you tap into a user group, they are usually willing to share.”
Knocking off the “Low-Hanging Fruit”
Once an application for the CRS is accepted, many communities struggle to identify which activities they should tackle first. Although FEMA actively discourages this type of thinking – in favor of designing the most appropriate floodplain management measures for a specific community – IBTS identified eleven activities that 75 to 100 percent of communities receive credit for.
Split into two categories, the first set of activities are basic requirements, that involve fewer resources, but offer less point credit than other, more difficult activities.
CRS Prerequisites/Basics/Lower Scoring
310 – Elevation Certificates – Prerequisite for all, a CRS program foundation
320 – FIRM – Flood Information Rate Maps must be publicly available
350 – Flood Protection Information – available in public library and online
630 – Dam Safety – credits received for a state-level program
440 – Flood Data Maintenance – GIS, computer-based
330 – Public Outreach – convey information publicly
340 – Hazard Disclosure – real estate agents provide information
The second category includes regulatory and maintenance measures that can receive much higher CRS credit, ranging from 560 to over 2,000 points. They also require action from the local government and/or outside agencies.
Regulatory/Open-Ended/Potentially High-Scoring
430 – Higher Regulatory Standards – above NFIP requirements (e.g., 2’ freeboard)
420 – Open Space Preservation – common non-structural flood mitigation measure
450 – Stormwater Management – regulates new construction
540 – Drainage System Maintenance – inspect and clear debris
While not all of these activities will be appropriate for every community, this list provides a starting point for jurisdictions looking to identify activities that may be pertinent to their communities. For more detail on these activities and a full list of CRS creditable measures, view FEMA’s CRS brochure