Flood Map Modernization
Federal Emergency Management Agency's Implementation of a National Strategy Gao ID: GAO-05-894T July 12, 2005Floods inflict more damage and economic losses upon the United States than any other natural disaster. During the 10 years from fiscal year 1992 through fiscal year 2001, flooding resulted in approximately $55 billion in damages. The Federal Emergency Management Agency (FEMA) is responsible for managing the National Flood Insurance Program (NFIP). The program uses flood maps to identify the areas at greatest risk of flooding and make insurance available to property owners to protect themselves from flood losses. According to FEMA, many of the nation's flood maps are more than 10 years old and no longer reflect current flood hazard risks because of erosion and changes in drainage patterns. Moreover, because many flood maps were created or last updated, there have been improvements in the techniques for assessing and displaying flood risks. This testimony is based on GAO's findings and recommendations in its March 2004 report related to (1) how map modernization intended to improve the accuracy and accessibility of the nation's flood maps, (2) what the expected benefits of more accurate and accessible flood maps are, and (3) to what extent FEMA's strategy for managing the map modernization program support the achievement of these benefits.
Through map modernization, FEMA intends to produce more accurate and accessible flood maps by using advanced technology to gather accurate data and make the flood maps available on the Internet. For example, displaying map data in digital Geographic Information Systems format permits consistent, accurate display, and ready electronic retrieval of a variety of map features, including elevation data and the location of key infrastructure, such as utilities. FEMA expects that by producing more accurate and accessible digital flood maps through map modernization, the nation will benefit in three ways. First, communities can use more accurate digital maps to reduce flood risk within floodplains by more effectively regulating development through zoning and building standards. Second, accurate digital maps available on the Internet will facilitate the identification of property owners who are statutorily required to obtain or who would be best served by obtaining flood insurance. Third, accurate and precise data will help national, state, and local officials to accurately locate infrastructure and transportation systems (e.g., power plants, sewage treatment plants, railroads, bridges, and ports) to help mitigate and manage risk for multiple hazards, both natural and man-made. At the time of GAO's review, FEMA had not yet established clear standards for the types, quantity, and specificity of data collection and analysis associated with different levels of flood risk. We recommended that FEMA develop standards to better ensure that data collection and analysis is consistent for all communities with similar risk and that it is using its resources efficiently while producing maps that are accurate and useful for communities at different levels of flood risk. In November 2004, FEMA issued its Multi-Year Flood Hazard Identification Plan. The plan describes FEMA's strategy for addressing GAO's recommendation by using varying types of data collection and analysis techniques to develop flood hazard data in order to relate the level of study and level of risk for each county. GAO concluded that FEMA's performance measures would not effectively measure the extent to which the agency's map modernization program would result in its primary intended benefits. As a result, GAO recommended that FEMA develop and implement useful performance measures. In response to GAO's recommendation, FEMA has set target percentages in its Multi-Year Flood Hazard Identification Plan for four key performance indicators in fiscal years 2006 through 2009. FEMA's four indicators are (1) Population with Digital GIS Flood Data Available Online, (2) Population with Adopted Maps that Meet Quality Standards, (3) Leveraged Digital GIS Flood Data, and (4) Appropriated Funds Sent to Coordinating Technical Partners.
GAO-05-894T, Flood Map Modernization: Federal Emergency Management Agency's Implementation of a National Strategy
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Testimony:
Before the Subcommittee on Housing and Community Opportunity, Committee
on Financial Services, House of Representatives:
United States Government Accountability Office:
GAO:
For Release on Delivery Expected at 10:00 a.m. EDT:
Tuesday, July 12, 2005:
Flood Map Modernization:
Federal Emergency Management Agency's Implementation of a National
Strategy:
Statement of William O. Jenkins, Jr., Director, Homeland Security and
Justice Issues:
GAO-05-894T:
GAO Highlights:
Highlights of GAO-05-894T, a report to Subcommittee on Housing and
Community Opportunity, Committee on Financial Services, House of
Representatives:
Why GAO Did This Study:
Floods inflict more damage and economic losses upon the United States
than any other natural disaster. During the 10 years from fiscal year
1992 through fiscal year 2001, flooding resulted in approximately $55
billion in damages. The Federal Emergency Management Agency (FEMA) is
responsible for managing the National Flood Insurance Program (NFIP).
The program uses flood maps to identify the areas at greatest risk of
flooding and make insurance available to property owners to protect
themselves from flood losses. According to FEMA, many of the nation's
flood maps are more than 10 years old and no longer reflect current
flood hazard risks because of erosion and changes in drainage patterns.
Moreover, because many flood maps were created or last updated, there
have been improvements in the techniques for assessing and displaying
flood risks.
This testimony is based on GAO‘s findings and recommendations in its
March 2004 report related to (1) how map modernization intended to
improve the accuracy and accessibility of the nation's flood maps, (2)
what the expected benefits of more accurate and accessible flood maps
are, and (3) to what extent FEMA's strategy for managing the map
modernization program support the achievement of these benefits.
What GAO Found:
Through map modernization, FEMA intends to produce more accurate and
accessible flood maps by using advanced technology to gather accurate
data and make the flood maps available on the Internet. For example,
displaying map data in digital Geographic Information Systems format
permits consistent, accurate display, and ready electronic retrieval of
a variety of map features, including elevation data and the location of
key infrastructure, such as utilities.
FEMA expects that by producing more accurate and accessible digital
flood maps through map modernization, the nation will benefit in three
ways. First, communities can use more accurate digital maps to reduce
flood risk within floodplains by more effectively regulating
development through zoning and building standards. Second, accurate
digital maps available on the Internet will facilitate the
identification of property owners who are statutorily required to
obtain or who would be best served by obtaining flood insurance. Third,
accurate and precise data will help national, state, and local
officials to accurately locate infrastructure and transportation
systems (e.g., power plants, sewage treatment plants, railroads,
bridges, and ports) to help mitigate and manage risk for multiple
hazards, both natural and man-made.
At the time of GAO‘s review, FEMA had not yet established clear
standards for the types, quantity, and specificity of data collection
and analysis associated with different levels of flood risk. We
recommended that FEMA develop standards to better ensure that data
collection and analysis is consistent for all communities with similar
risk and that it is using its resources efficiently while producing
maps that are accurate and useful for communities at different levels
of flood risk. In November 2004, FEMA issued its Multi-Year Flood
Hazard Identification Plan. The plan describes FEMA‘s strategy for
addressing GAO‘s recommendation by using varying types of data
collection and analysis techniques to develop flood hazard data in
order to relate the level of study and level of risk for each county.
GAO concluded that FEMA‘s performance measures would not effectively
measure the extent to which the agency‘s map modernization program
would result in its primary intended benefits. As a result, GAO
recommended that FEMA develop and implement useful performance
measures. In response to GAO‘s recommendation, FEMA has set target
percentages in its Multi-Year Flood Hazard Identification Plan for four
key performance indicators in fiscal years 2006 through 2009. FEMA‘s
four indicators are (1) Population with Digital GIS Flood Data
Available Online, (2) Population with Adopted Maps that Meet Quality
Standards, (3) Percent of Effort Leveraged; that is, state and local
resources provided for map modernization as a percentage of FEMA
resources provided, and (4) Appropriated Funds Sent to Coordinating
Technical Partners.
www.gao.gov/cgi-bin/getrpt?GAO-05-894T.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact William O. Jenkins, Jr.
at (202) 512-8757 or jenkinswo@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
I appreciate the opportunity to participate in today's hearing to
discuss the Federal Emergency Management Agency's (FEMA) national flood
map modernization program.[Footnote 1] My testimony is primarily based
on our March 2004 report on FEMA's map modernization efforts.[Footnote
2]
Floods inflict more damage and economic losses upon the United States
than any other natural disaster. During the 10 years from fiscal year
1992 through fiscal year 2001, flooding caused over 900 deaths and
resulted in approximately $55 billion in damages.[Footnote 3] Since its
inception 36 years ago, the National Flood Insurance Program (NFIP) has
combined the development of flood maps to identify the areas at
greatest risk of flooding with mitigation[Footnote 4] efforts to reduce
or eliminate flood risks to people and property and the availability of
insurance that property owners can purchase to protect themselves from
flood losses. The flood insurance program has paid about $12 billion in
insurance claims, primarily from policyholder premiums, that otherwise
would have been paid, at least in part, from taxpayer-funded disaster
relief.
Accurate flood maps that identify the areas at greatest risk of
flooding are the foundation of the NFIP. The maps are principally used
by (1) the approximately 20,000 communities participating in the NFIP
to adopt and enforce the program's minimum building standards for new
construction within the maps' identified floodplains, (2) FEMA to
develop accurate flood insurance policy rates based on flood risk, and
(3) federally regulated mortgage lenders to identify those property
owners who are statutorily required to purchase federal flood
insurance. Under the National Flood Insurance Act of 1968, as
amended,[Footnote 5] property owners whose properties are within the
designated floodplain and have a mortgage from a federally regulated
financial institution are required to purchase federal flood insurance.
Flood maps can become outdated for a variety of reasons, such as
erosion or community growth and development that can affect the
drainage patterns of rainwater. Thus, flood maps must be periodically
updated to assess and map changes in the boundaries of floodplains that
result from community growth, development, erosion, and other factors
that affect the boundaries of areas at risk for flooding.
With congressional support and funding, last year FEMA embarked on a $1
billion, 5-year effort to update the nation's flood maps. Today, I am
here to discuss the findings and recommendations of our March 2004
report. My remarks today will focus on (1) how map modernization is
intended to improve the accuracy and accessibility of the nation's
flood maps; (2) what the expected benefits of more accurate and
accessible flood maps are; and (3) to what extent FEMA's strategy for
managing the map modernization program supports the achievement of
these benefits.
To answer these questions, we analyzed available information from FEMA
on the program's purpose, objectives, and status and met with agency
officials in headquarters and in the regional offices to discuss the
program's progress. We also conducted site visits to states and
communities that have already begun to modernize their flood maps and
interviewed industry organizations such as the Association of State
Flood Plain Managers, the National Association of Flood and Stormwater
Management Agencies, and the National Emergency Management Association.
We conducted our work from April 2003 to March 2004 in accordance with
generally accepted government auditing standards.
Summary:
In summary, we found:
* Through map modernization, FEMA intends to produce more accurate and
accessible flood maps by using advanced technology to gather accurate
data and make the flood maps, and the digital information on which they
are based, available on the Internet. For example, displaying map data
in digital Geographic Information Systems (GIS) format permits
consistent, accurate display, and ready electronic retrieval of a
variety of map features, including elevation data and the location of
key infrastructure, such as utilities. According to FEMA, nearly 70
percent of the nation's approximately 92,222 flood maps were more than
10 years old at the time of our review. Many of these maps no longer
reflect current flood hazard risks because changes such as erosion and
development can alter drainage patterns and, thus, the areas at highest
risk of flooding. Moreover, since many flood maps were created or last
updated, there have been improvements in the techniques for assessing
and displaying flood risks.
* FEMA expects that by producing more accurate and accessible digital
flood maps through map modernization, the nation will benefit in three
ways. First, communities can use more accurate digital maps to reduce
flood risk within floodplains by more effectively regulating
development through zoning and building standards. Second, accurate
digital maps available on the Internet will facilitate the
identification of property owners who are statutorily required to
obtain or who would be best served by obtaining flood insurance. Third,
accurate and precise data will help national, state, and local
officials to accurately locate infrastructure and transportation
systems (e.g., power plants, sewage treatment plants, railroads,
bridges, and ports) to help mitigate and manage risk for multiple
hazards, both natural and man-made.
* FEMA's strategy for managing map modernization is designed to support
the expected program benefits, but FEMA's approach to implementing the
strategy raised several concerns that we concluded could hamper the
agency's efforts. FEMA's implementation approach is based on four
objectives: (1) establish and maintain a premier data system, (2)
expand outreach and better inform the user community, (3) establish and
maintain effective partnerships, and (4) achieve effective program
management.
* Establish and maintain a premier data system: Although FEMA's efforts
to establish a new data system could result in more accurate flood maps
and make it easier to access and use the revised flood maps, at the
time of our review, FEMA had not yet established clear standards for
the types, quantity, and specificity of data collection and analysis
associated with different levels of flood risk. FEMA had ranked the
nation's 3,146 counties from highest to lowest flood risk. According to
FEMA, communities at the highest risk of flooding require the most
extensive, detailed data and analysis, but the same level of data
collection and analysis may not be necessary to create accurate, useful
maps for communities with lower flood risks. Defining the level of data
collection and analysis for different levels of risk are important
because obtaining and analyzing flood map data is time-consuming and
expensive, and the more detailed and specific the data, generally the
greater the effort and costs required to obtain it. By identifying the
types, quantity, and specificity of the data and analysis needed for
communities based on their risk, we concluded that FEMA could better
ensure that data collection and analysis is consistent for all
communities with similar risk and that it is using its resources
efficiently while producing maps that are accurate and useful for
communities at different levels of flood risk. FEMA acknowledged the
need to develop such standards, but, at the time of our review, had not
yet developed draft standards or included this task into its map
modernization implementation plan. In November 2004, FEMA issued its
Multi-Year Flood Hazard Identification Plan. The plan describes FEMA's
strategy for addressing our concerns and discusses the varying types of
data collection and analysis techniques the agency plans to use to
develop flood hazard data in order to relate the level of study and
level of risk for each county.
* Expand outreach and better inform the user community: FEMA's planned
expanded outreach efforts are intended to increase public awareness and
obtain community acceptance of the updated flood maps because the
updated information could potentially identify changes in floodplain
boundaries and, therefore, affect property owners, including whether or
not their property's location may require them to purchase federal
flood insurance. FEMA's intended outcome for these outreach efforts is
to reduce community vulnerability to natural and man-made hazards and
increase participation in the flood insurance program. Because FEMA
does not have the authority to require that affected property owners
take steps to protect their properties against flood risks or to ensure
that owners whose properties are in the floodplain purchase flood
insurance, effective outreach is essential to ultimately achieve these
benefits.
* Establish and maintain effective partnerships: FEMA's objective for
building and maintaining mutually beneficial partnerships is designed
to facilitate and support the efficient production and effective use of
maps. FEMA recognizes that local, state, and federal agencies that have
been working on mapping activities for years, have the resources and
potential to positively affect the quality and quantity of the data
collected and improve the way these data are used. In addition, these
partnerships can enable FEMA to leverage its resources and reduce the
federal costs of map modernization. FEMA had developed a strategy for
partnering with these agencies to encourage greater involvement in map
modernization, including the contribution of resources. However, we
concluded that the overall effectiveness of the agency's partnering
efforts was uncertain because FEMA had not yet developed a clear
strategy for partnering with communities that have few resources,
limited mapping capability, and little history of flood mapping
activities. FEMA's Multi-Year Flood Hazard Identification Plan (the
Plan) does not explicitly address such strategies. For fiscal year
2004, the Plan notes that, nationwide, dollars leveraged from local,
non-FEMA sources substantially exceeded the target level of 20 percent,
with 36 percent of the effort leveraged from other partners. In 4 of
the 10 FEMA regions the leverage exceeded 40 percent. However, in 3 of
the 10 FEMA regions the leverage was less than 10 percent. This
experience, along with a projected 50 percent increase in the total
cost of the program, supports the need for strategies to address
disparities and maximize map modernization stakeholders' contributions
to the program.
* Achieve effective program management: In March 2004, FEMA awarded a
performance-based contract to a single contractor to oversee map
modernization that includes performance measures to gauge the success
of its efforts. Through a staffing analysis, FEMA had determined that
it needed 75 staff with specific, identified skills to effectively
monitor and manage the contract and overall map modernization program.
As of March 2004, FEMA had hired 1 of the 75 staff, and had developed
plans to hire or transfer 43 others, but had not yet determined how it
would acquire the remaining 31 positions. In addition, we found that
FEMA had not clearly defined performance measures related to whether
(1) the revised maps meet any established standards for accuracy and
(2) outreach efforts are successful in increasing the community and
individual awareness and use of flood maps. In response to our
recommendation, FEMA's set goals in its November 2004 Multi-Year Flood
Hazard Identification Plan for key performance indicators. FEMA's four
indicators are (1) Population with Digital GIS Flood Data Available
Online, (2) Population with Adopted Maps that Meet Quality Standards,
(3) Percent of Effort Leveraged; that is, state and local resources
provided for map modernization as a percentage of FEMA resources
provided, and (4) Appropriated Funds Sent to Cooperating Technical
Partners (CTP). To track its progress of map modernization annually,
FEMA set target percentages for achieving these performance indicators
in fiscal years 2006 through 2009.
Map Modernization Intends to Use Advanced Technologies to Produce More
Accurate and Accessible Digital Flood Maps:
Through map modernization, FEMA intends to produce more accurate and
accessible flood maps by using advanced technology to gather accurate
data and make the resulting information available on the Internet. Many
of the flood maps in FEMA's inventory do not accurately reflect the
true flood hazard risks because over time, new development and other
factors altered watersheds and floodplains faster than the maps could
be updated. Prior to fiscal year 2004, the $35 million to $50 million
in annual flood insurance policy fees had been the only source of
funding for updating flood maps, and according to FEMA, the agency had
not been able to keep the maps updated with the funds available. As a
result, at the time of our review, nearly 70 percent of the nation's
approximately 92,222 flood maps[Footnote 6] were more than 10 years old
and many contain inaccurate data, according to FEMA.
Over time, physical conditions in watersheds and floodplains can
change, and improvements in the techniques for assessing and displaying
flood risks are made. FEMA plans to use the latest technology, such as
GIS, to create accurate digital flood maps. GIS technology provides the
foundation for achieving FEMA's goals of melding different types and
sources of data to create the new digital flood maps and making the new
digital flood maps available to a variety of users over the Internet.
The primary function of GIS is to link multiple digital databases and
graphically display that information as maps with potentially many
different types of "layers" of information. When layers of information
are formatted using the same standards, users can potentially overlay
various layers of information about any number of specific topics to
examine how the layers interrelate. Each layer of a GIS map represents
a particular "theme" or feature, and one layer could be derived from a
data source completely different from the other layers. For example,
one theme could represent all the streets in a specified area. Another
theme could correspond to the topography or elevation data of an area,
and others could show aerial photography and streams in the same area.
These themes are all key elements needed to create flood maps that
accurately depict floodplains and can be used to identify properties in
these areas. In preparing for full-scale implementation of map
modernization, FEMA had established standards and graphic
specifications for digital flood maps created with GIS.
GIS technology also enables the creation of more accurate and
accessible maps than would be possible with older mapping methods and
technology. The majority of FEMA's flood map inventory was produced
using manual techniques that have inherent accuracy and accessibility
limitations. For example, in creating traditional paper flood maps,
field measurements taken by surveyors would have been transferred by
hand to paper base maps. If the paper base map contained any
inaccuracies, then the field-survey data could be shown in the wrong
place on the final flood map. This would then result in floodplain
boundaries being shown in the wrong place.
By their nature, paper flood maps have limited accessibility as
compared with a digital map that can be made available on the Internet.
The expansion of Internet connectivity in recent years has
substantially enhanced the potential value of digital maps created with
GIS because now it is possible to locate and connect data from many
distinct GIS databases to develop analytical information on almost any
topic that is associated with physical locations. Digital flood maps
created according to FEMA's standards are intended to provide users not
only with the ability to determine the flood zone and base flood
elevations for a particular location, but also with the ability to
access other information like road, stream, and public land survey
data. Communities could use this information for a variety of purposes,
including decisions on future development and evacuation routes.
As part of map modernization, FEMA has promoted the use of a variety of
advanced technologies to improve the accuracy of flood maps. In recent
years, for example, where it deems it appropriate, FEMA has promoted
the use of Light Detection and Ranging (LIDAR) remote sensing
technologies to generate highly detailed, digital elevation data.
Elevation data are a key component needed to determine flood risk and
identify floodplain boundaries. According to FEMA, for very flat areas
where small changes in elevation can have a large impact on where flood
plain boundaries are drawn, LIDAR can provide the level of detail
needed to accurately delineate these boundaries. Communities can also
use detailed, digital elevation data for planning and land development
purposes.
FEMA Expects Map Modernization to Increase the Likelihood Maps Will Be
Used for Risk Management:
FEMA expects map modernization to increase the likelihood that the more
accurate and accessible maps will be used for risk management purposes.
Specifically, FEMA expects the new maps to be used to (1) improve flood
mitigation, (2) increase flood insurance participation, and (3) improve
"multi-hazard" mitigation and risk management capabilities. First, FEMA
expects communities to be able to use these new and revised maps to
better manage and mitigate flood risk by regulating floodplain
development through building codes, ordinances, and regulations.
Second, the new maps also have the potential to help increase flood
insurance participation because they will more accurately identify
those properties that are in the floodplain and whose owners would be
required to purchase flood insurance. Third, the data and
infrastructure developed by map modernization is also expected to help
national, state, and local officials mitigate and manage risk from
multiple hazards, both natural and man-made. Accurate digital maps can
provide more precise data on such things as the location of hazardous
material facilities, power plants, railroads, and airports to state and
national officials for planning development as well as to assess
internal weaknesses and evacuation routes.
Map Modernization Is Expected to Improve Flood Mitigation:
The more accurate and updated flood hazard information produced through
map modernization is expected to help improve flood mitigation in
participating communities. The NFIP requires participating communities
to adopt and enforce building standards based on the floodplain
boundaries and base flood elevations when maps are updated. For
example, the lowest floor of structures in new construction must be
elevated to at least the base flood elevations identified on the maps.
FEMA's policy is to monitor communities to ensure that they have
adopted building standards that meet the minimum NFIP criteria and to
ensure that they are effectively enforcing these standards. If
communities fail to establish and enforce minimum NFIP flood plain
building standards, FEMA can suspend availability of federal flood
insurance.
Communities also may use updated flood hazard data to take actions to
mitigate flooding that go beyond adopting the building standards
required by the NFIP. For example, communities may use the data from
the maps to identify where to conduct capital improvement projects
designed to mitigate flooding of structures in the floodplain. In
addition, FEMA has established a Community Rating System that provides
discounts on flood insurance premiums for those communities that take
mitigation actions beyond those required by the NFIP.
Map Modernization Is Expected to Help Increase Flood Insurance
Participation:
Map modernization has the potential to help increase flood insurance
participation. The accuracy of the new maps should better identify at-
risk property owners who would be best served by obtaining flood
insurance whether or not the owners would be required to purchase
insurance under the NFIP's mandatory purchase requirement. Moreover,
the digital, GIS-based maps should make flood risk information more
accessible to a variety of users such as lenders and community
officials who could conduct targeted outreach to these property owners.
It is important to note, however, that FEMA, states, and communities do
not have the authority to ensure that property owners who are subject
to the mandatory purchase of flood insurance requirement actually
purchase flood insurance. It is the federally regulated lenders'
responsibility to ensure that borrowers purchase flood insurance and
that the insurance policy is maintained throughout the loan's life as
each new lender servicing the loan becomes aware that the affected
property is at risk for flooding. Furthermore, owners of properties
without mortgages or properties with mortgages held by unregulated
lenders are not required to purchase flood insurance, even if the
properties are in floodplains.
Map Modernization Is Expected to Improve Multi-Hazard Mitigation and
Risk Management Capabilities:
FEMA expects that the data developed, collected, and distributed
through map modernization will help national, state, and local
emergency managers mitigate and manage risk posed by other natural and
man-made hazards. Accurate digital base maps provide more precise data
to state and national officials for planning, such as the location of
hazardous material facilities, power plants, utility distribution
facilities, and other infrastructure (bridges, sewage treatment plants,
buildings, and structures). According to FEMA, map modernization will
also support DHS's overall goal to reduce the nation's vulnerability to
terrorism by providing GIS data and capabilities to other departmental
functions. For example, more accurate information on transportation
systems such as railroads, airports, harbors, ports, and waterways
should be helpful in assessing internal weaknesses and evacuation
routes.
FEMA's Strategy for Map Modernization Shows Promise, but Challenges
Remain:
FEMA's strategy for managing map modernization is intended to support
the achievement of the expected program benefits of improved flood
mitigation, increased NFIP insurance participation, and improved multi-
hazard mitigation and risk management capabilities. However, in
reviewing FEMA's approach to implementing the strategy, we identified
several challenges that could hamper the agency's efforts. FEMA's
approach is based on four objectives. Two objectives FEMA hopes to
achieve through map modernization--building and maintaining a premier
data collection and delivery system and expanding outreach and better
informing the user community--have the potential to improve the use of
flood maps for improved flood mitigation and increased NFIP
participation, as well as multi-hazard risk management. The other two
objectives--building and maintaining mutually beneficial partnerships
and achieving effective program management--are intended to facilitate
the achievement of the first two objectives and their intended benefits
efficiently and effectively.
In Its Efforts to Establish a New Data System, FEMA Had Not Yet
Established Data Standards for Different Levels of Risk:
The goal of FEMA's objective to develop a new data system using the
latest technology is more efficient production, delivery and, thereby,
the use of flood maps. As discussed previously, FEMA hopes to
accomplish this by using geographic information systems technology that
provides the foundation for the production and delivery of more
accurate digital flood maps and multi-hazard data that is more
accessible over the Internet.
In developing the new data system to update flood maps across the
nation, FEMA's intent is to develop and incorporate flood risk data
that are of a level of specificity and accuracy commensurate with
communities' relative flood risks. According to FEMA, there is a direct
relationship between the types, quantity, and detail of the data and
analysis used for map development and the costs associated with
obtaining and analyzing those data. FEMA believes it needs to strike a
balance between the relative flood risk faced by individual communities
and the level of analysis and effort needed to develop reliable flood
hazard data if it is to update the nation's maps efficiently and
effectively.
FEMA ranked all 3,146 counties from highest to lowest based on a number
of factors, including, among other things, population, growth trends,
housing units, flood insurance policies and claims, repetitive loss
properties, and flood disasters. On the basis of this ranking, FEMA
established mapping priorities. However, at the time of our review,
FEMA had not established standards on the appropriate data and level of
analysis required to develop maps based on risk level. FEMA had
historically applied the same minimum standards for all flood maps and
supporting data.[Footnote 7] FEMA's Guidelines and Specifications for
Flood Hazard Mapping Partners provided guidance for selecting the level
of analysis and effort to produce flood hazard data and the guidelines
had generally been used on a case-by-case basis.[Footnote 8] We found
that the guidelines do not specify standards to be used for all mapping
projects within a given risk category and concluded that, without
establishing standards for different categories of risk, FEMA could not
ensure that it uses the same level of data collection and analysis
across all communities within the same risk category. These standards
could also provide a consistent basis for estimating the costs of
developing maps in each risk category. At the time of our review, FEMA
had not yet developed draft standards or incorporated this task into
its implementation plan. As a result, we recommended that FEMA develop
and implement data standards that would enable FEMA, its contractor,
and its state and local partners to identify and use consistent data
collection and analysis methods for communities with similar risk.
In November 2004, FEMA issued its Multi-Year Flood Hazard
Identification Plan. The plan describes FEMA's strategy for updating
flood maps used for NFIP purposes and discusses the varying types of
data collection and analysis techniques the agency plans to use to
develop flood hazard data in order to relate the level of study and
level of risk for each county.
FEMA's Objective to Expand Outreach Efforts Recognizes the Agency Must
Rely on Others to Achieve Map Modernization Benefits:
FEMA's objective to expand the scope and frequency of its outreach
efforts is intended to increase community and public acceptance of
revised maps and use of those maps. Historically, FEMA has only
contacted communities when initiating remapping and again when
preliminary maps are completed. These expanded outreach efforts reflect
FEMA's understanding that it is dependent on others to achieve the
benefits of map modernization. For example, under the structure of the
NFIP, FEMA is dependent on communities to adopt and enforce FEMA's
minimum building standards and on mortgage lenders to ensure compliance
with mandatory flood insurance purchase requirements. To expand the
scope of its outreach efforts, FEMA plans to involve a wide variety of
community participants--e.g., mayors, emergency managers, lenders,
property owners, insurance agents, and developers--in the mapping
process. To expand the frequency of outreach, FEMA intends to increase
community involvement, awareness, and participation throughout the
entire flood mapping process. Through a continual education process,
FEMA's goal is to inform property owners and others potentially
affected by remapping efforts of steps they can take to mitigate the
risk of flooding, the types of damage and costs caused by flooding, and
the benefits of flood insurance.
According to FEMA, if a community is involved in and understands the
map modernization process, the community is more likely to accept and
trust the accuracy of the final, revised maps and is more likely to use
the maps' hazard data to mitigate natural and man-made disasters.
Conversely, if affected property owners do not understand why their
communities are being mapped (or remapped) or why their property is now
in a flood zone, the unexpected additional expense of new or increased
flood insurance premiums can form the basis of significant community
opposition to map modernization activities and lead to formal appeals,
litigation, and delays in implementing map changes.
FEMA's expanded outreach efforts are intended to educate the public of
the potential flood risk in communities and to encourage them to take
action. Communities that participate in the NFIP are required to
establish floodplain management ordinances that require new and
substantially improved structures in newly designated floodplains to
meet NFIP building standards. However, if a property was not located in
the floodplain in the old map but is in the floodplain in the new
revised map, NFIP floodplain management regulations do not require
those owners to implement mitigation measures unless they make
substantial improvements to the structure.[Footnote 9] FEMA cannot
compel affected property owners to take steps to protect their
properties against flood risks or to purchase flood insurance. Under
current notification requirements, federally regulated lenders, not
FEMA, serve as the primary channel for notifying property owners whose
mortgaged properties are subject to flood insurance requirements. When
property owners seek new financing, through purchase or refinancing,
federally regulated mortgage lenders are required to determine if the
property is in the floodplain and, if so, require the purchase of flood
insurance. Lenders are not required to monitor map changes or to notify
property owners with existing mortgages whose properties are identified
in a floodplain by remapping if they are not aware of the change in
status.[Footnote 10]
Nonetheless, if federally regulated lenders become aware of flood map
changes that affect properties for which they hold mortgages through
FEMA notifications or flood zone determination companies,[Footnote 11]
then they must notify the property owner and require the purchase of
flood insurance. The information that must be provided to property
owners is limited to notifying property owners that their structure is
in a floodplain, providing a definition of a flood plain, and requiring
the purchase of flood insurance if they live in a participating NFIP
community. As a result, FEMA's outreach efforts are important for
supplementing the formal requirements for notifying communities and
property owners of map changes.
FEMA's Strategy for Partnering with States and Local Communities Does
Not Include Communities with Few Resources to Assist in Flood Mapping:
FEMA's objective for building and maintaining mutually beneficial
partnerships is intended to facilitate and support the efficient
production and effective use of flood maps. According to FEMA, local,
state, and federal partners that have invested resources and assisted
in managing mapping activities have the potential to positively affect
the detail, accuracy, and quantity of the data collected and improve
how these data are used. As part of their strategy for partnering, FEMA
provides guidance to the states on how to develop "business plans" that
document planned efforts to develop states' and communities' capability
and capacity to oversee the collection, analysis, and implementation of
flood data in their state and community and to justify funding for
these efforts. According to FEMA, 38 states had begun drafting such
plans. FEMA intends to use these state business plans to help
prioritize its continuing efforts to develop map modernization
partners.
Through its CTP program, FEMA has developed partnerships with a variety
of states and communities that have developed their own data and
provided their own funds to help update local flood maps. Since 2000,
FEMA has leveraged millions of dollars in funding from 171 partners
(states and local communities) for producing maps through its CTP
program. For example, from fiscal years 2000 to 2002, FEMA used $70
million of its federal map modernization funding along with state and
local funds to develop what FEMA has estimated to be more than $155
million worth of new mapping data. According to FEMA, partnering has
other benefits as well. For example, in the long-term, those states and
communities with whom FEMA has established partnerships may be more
likely to accept final map changes, expand their capabilities, and
assume greater responsibility for periodically developing and
incorporating updated flood data, resulting in cost savings to FEMA.
Some states and communities with few resources and technical capacities
or little history of flood mapping activities are likely to pose a
challenge to FEMA's ability to fund and implement mapping activities.
For example, we talked with flood management officials in several
smaller communities in Montgomery County, Texas; Santa Cruz County,
Arizona; and Larkspur, Colorado. These officials said that their
communities lacked either the funding needed to develop flood data, the
technological capability to develop digital flood data and use
geospatial information systems, or, in some cases, the community
support needed to conduct mapping activities. One approach for
obtaining additional resources, capabilities, and community support
would be for FEMA to facilitate coordination with other agencies within
the state that have a stake in, or could benefit from, mapping
activities. For example, state departments of transportation can
benefit from information in FEMA's geospatial information system, such
as elevation data, in planning and building state roads and bridges.
North Carolina was able to get its state transportation department to
help fund the development of elevation data used for flood maps. At the
time of our review, FEMA had not yet developed a strategy for how to
partner with communities that do not have the resources, capabilities,
or motivation to initiate and sustain mapping activities. Such a
strategy could focus on how to assist these potential partners in
garnering community resources and developing technological
capabilities, how to coordinate with other agencies in their state, and
how to integrate these efforts with FEMA's community outreach efforts
to gain community support for mapping activities. As a result, we
recommended that FEMA develop and implement strategies for partnering
with state and local entities with varying levels of capabilities and
resources. FEMA's Plan does not explicitly address such strategies. For
fiscal year 2004, the Plan notes that, nationwide, dollars leveraged
from local, non-FEMA sources substantially exceeded the target level of
20 percent, with 36 percent of the effort leveraged from other
partners. In 4 of the 10 FEMA regions the leverage exceeded 40 percent.
However, in 3 of the 10 FEMA regions the leverage was less than 10
percent. This experience, along with a projected 50 percent increase in
the total cost of the program, supports the need for strategies to
address disparities and maximize map modernization stakeholders'
contributions to the program.
Program Management Contract Is Performance-Based, but FEMA May Have
Difficulty Overseeing the Contract and Measuring Achievement of Program
Objectives:
In March 2004, FEMA awarded a performance-based contract to obtain
assistance from a nationwide mapping contractor to manage tasks
associated with the significant expansion of the map modernization
program. Unlike many traditional government service contracts, which
emphasize inputs rather than outcomes, a performance-based contracting
approach gives the contractor the flexibility to determine how best to
achieve the outcomes and links payment to the contractor's ability to
achieve these outcomes--an approach supported by our past work in
federal contracting. Overseeing these types of contracts requires
agency staff with the knowledge, skills, and abilities to monitor the
contractor's efforts using performance measures that accurately measure
agreed-upon outcomes.
We concluded that FEMA might be limited in its ability to effectively
manage the contract, as well as the significant expansion of tasks
associated with a five-fold increase in funding and related mapping
activities that will continue to be performed by agency staff. These
tasks include managing grants for many new mapping partners and
administering contracts with independent firms to develop and process a
significantly larger quantity of flood data to support local efforts. A
staffing needs assessment completed by FEMA in December 2003 identifies
a need for an additional 75 staff with additional skills, including
contracting and program management capabilities. In appropriating
fiscal year 2004 map modernization funds, Congress included a provision
that would allow FEMA to use up to 3 percent, or $6 million, for
administrative purposes. As of March 2004, FEMA had filled 1 of the 75
positions by reallocating existing resources. At the time of our review
FEMA planned to fill another 33 positions using the administrative
funding identified in the fiscal year 2004 budget. In addition, FEMA
also planned to fill an additional 10 positions by moving staff from
other FEMA departments or filling vacancies. However, at the time of
our review, FEMA had not yet established a plan for filling the
remaining 31 headquarters and regional positions. As a result, we
recommended that FEMA ensure that it has the staff capacity to
effectively implement the nationwide mapping contract and the overall
map modernization program.
One element of effective program management is establishing performance
measures to determine how well FEMA is achieving its map modernization
program objectives. FEMA had established performance measures for all
four of its program objectives. However, we concluded that FEMA's
measures for two of those objectives that directly support the use of
flood maps for risk management--to develop a premier data system and to
expand and better inform the user community were not clearly defined or
fully developed. FEMA's principal measure for developing and
maintaining a premier data collection and delivery system is the
percent of the national population with community-adopted, GIS data-
based flood maps. However, this measure does not indicate whether the
maps themselves meet any FEMA-established standards for accuracy
(because FEMA had not yet defined the minimum level of data collection
and analysis for communities with similar risk).
To measure the progress and success of expanding and better informing
the user community, FEMA established performance measures related to
the percent increase in communities' awareness and use of new maps.
FEMA plans to use surveys as the primary means of measuring increased
community awareness and use of the new maps. However, FEMA had not yet
fully developed an operational definition of how it plans to measure
"awareness" or "use," for example, that reflect mitigation steps taken
or the purchase of flood insurance. Because the link between revising
maps and the use of maps in terms of increased NFIP participation is
not direct, we recognized that it may be a challenge to develop a
performance measure that accurately reflects the impact on NFIP
participation rates of efforts to expand and improve outreach.
Nonetheless, without developing such a measure (or measures), we
concluded that FEMA would be less able to ensure that its map
modernization program will have resulted in one of FEMA's primary
intended benefits. As a result, we recommended that FEMA develop and
implement useful performance measures that define FEMA' s progress in
increasing stakeholders' awareness and use of the new maps, including
improved mitigation efforts and increased participation rates in
purchasing flood insurance.
In response to our recommendation, FEMA's set goals in its November
2004 Multi-year Flood Hazard Identification Plan to improve public
safety through the availability of reliable flood risk data.
Specifically, FEMA plans to increase the safety for at least 85 percent
of the U.S. population through availability of accurate flood risk data
in GIS format. To achieve this goal, FEMA has set targets for key
performance indicators (KPI) through fiscal year 2009 (production is
scheduled for completion in fiscal year 2010). FEMA's four KPIs are (1)
Population with Digital GIS Flood Data Available Online, (2) Population
with Adopted Maps that Meet Quality Standards, (3) Percent of Effort
Leveraged; that is, state and local resources provided for map
modernization as a percentage of FEMA resources provided, and (4)
Appropriated Funds Sent to CTPs. To track its progress of map
modernization annually, FEMA set target percentages for achieving these
performance indicators in fiscal years 2006 through 2009.
Mr. Chairman and Members of the Committee, this concludes my prepared
statement. I would be pleased to answer any questions you and the
Committee Members may have.
Contact and Staff Acknowledgments:
For further information about this statement, please contact William O.
Jenkins, Jr. Director, Homeland Security and Justice Issues on (202)
512-8777 or jenkinswo@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made major contributors to this
testimony included Grace Coleman, Christopher Keisling, Raul Quintero,
and John Vocino.
FOOTNOTES
[1] Prior to March 2003, FEMA was an independent agency whose Federal
Insurance and Mitigation Administration was responsible for managing
the flood insurance program. The Homeland Security Act of 2002, P.L.
107-296 (Nov. 25, 2002), transferred FEMA and all its responsibilities
to the Emergency Preparedness and Response Directorate within the new
Department of Homeland Security. This transfer was effective March 1,
2003. Currently, the Mitigation Division within FEMA is responsible for
the flood insurance program, including flood map modernization.
[2] GAO, Flood Map Modernization: Program Strategy Shows Promise, but
Challenges Remain, GAO-04-417, (Washington, D.C.: March 31, 2004)
[3] Data are from the U.S. Army Corps of Engineers in cooperation with
the National Weather Service.
[4] Mitigation is defined by the Federal Emergency Management Agency as
sustained action that reduces or eliminates long-term risk to people
and property from hazards and their effects.
[5] See 42 U.S.C. 4001 et seq.
[6] The 92,222 flood maps represent nearly 20,000 communities.
[7] For example, FEMA implemented digital base map standards in 1998
and LIDAR standards in 2000.
[8] These guidelines describe detailed methods of analysis used for
high-risk areas and less detailed methods used for low-risk areas.
[9] If a community determines that the cost of improvements to a home
or business equals or exceeds 50 percent of the market value of the
building, the building is considered a "substantial improvement" and
must meet the NFIP's minimum requirements.
[10] In making loans, federally regulated lenders are required to
ensure that property owners purchase flood insurance if their mortgages
are secured by a structure located in a floodplain. Lenders are also
required to check the flood hazard status of a property when triggered
by statutory tripwires, such as loan renewal or extension.
[11] Many lenders use flood zone determination companies to determine
whether properties require flood insurance as a result of loan
origination, loan assumption, or map changes. These companies use FEMA
flood maps and other data to ascertain if properties are situated in
flood zones.
