FEMA Flood Maps
Some Standards and Processes in Place to Promote Map Accuracy and Outreach, but Opportunities Exist to Address Implementation Challenges
Gao ID: GAO-11-17 December 2, 2010
The Federal Emergency Management Agency (FEMA), a component of the Department of Homeland Security (DHS), maps flood hazard areas across the country and makes flood insurance available to more than 20,100 communities through the National Flood Insurance Program. From 2003 through 2008, FEMA spent $1.2 billion in a comprehensive effort to update the nation's flood insurance maps. In 2009, FEMA began an annual review of 20 percent of the nation's flood maps, for which Congress allocated $440 million in 2009 and 2010. As requested, GAO reviewed the actions FEMA has taken to enhance the accuracy of updated flood maps, and FEMA's outreach efforts in conducting flood mapping activities. GAO analyzed FEMA's mapping standards and information systems, tested quality assurance processes, and interviewed FEMA officials and contractors.
FEMA has taken a number of steps to enhance the accuracy of flood maps, but challenges related to implementing standards to ensure map accuracy remain. Steps FEMA has taken include adopting a risk-based method to prioritize mapping projects, implementing mapping standards and guidance, establishing risk-based standards for topographic detail to ensure that the highest risk areas have the most accurate topographic data, and implementing quality control processes for ensuring engineering data is collected and used in accordance with standards. However, FEMA's mapping standards could be improved. For example, FEMA has standards for determining the extent to which new and updated flood mapping data are sufficiently current to promote map accuracy, yet FEMA has not developed uniform guidance for the validation of existing mapping data. Doing so could help FEMA both track and report the accuracy of maps at the national and regional levels and better assess mapping data needs. FEMA's quality control process for ensuring the accuracy of flood maps could also be improved. Audits of FEMA's mapping contractors' efforts have been conducted since 2006 by an independent verification contractor; however, FEMA officials said they planned to transfer responsibility for the verification audits, part of its independent verification and validation process, to its program management contractor by the end of this year, who will then monitor FEMA's mapping contractors. The transfer of these responsibilities creates a potential conflict of interest because the program management contractor is to monitor the results of its program management efforts. According to industry best practices, verification and validation efforts should be independent and reported directly to senior management to provide added assurance that reported results on the project's status are unbiased. The performance of the verification and validation function by an entity that is technically, managerially, and financially independent of the organization in charge of what it is assessing could better position FEMA to help ensure the independence of the verification and validation function, both in appearance and in fact. FEMA has taken a variety of steps to conduct outreach to state and local officials, including developing a national outreach strategy, but could enhance its efforts to improve public awareness and promote map acceptance. For example, FEMA has not developed performance goals or measures, or identified the resources needed for its flood mapping outreach efforts, which could help FEMA better determine whether its outreach efforts are achieving their intended results. In addition, FEMA could better quantify, allocate, and leverage resources needed to support national outreach efforts. For example, by tracking spending and using risk in its decisions for allocating outreach resources, FEMA could better allocate resources for flood mapping outreach efforts. In addition, FEMA could enhance its outreach efforts by leveraging existing flood insurance marketing resources and expertise during the mapping process to increase public acceptance of flood maps. Among other things, GAO recommends that FEMA establish guidance for validating data, transfer responsibility for verification audits to an independent entity, and establish goals and measures for promoting public acceptance of mapping. FEMA concurred with 10 of the 11 recommendations in this report, but disagreed with transferring verification audit duties to an independent entity because it believes its program management contractor is sufficiently independent. GAO believes this recommendation remains valid as stated in this report.
Recommendations
Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director:
William O. Jenkins Jr
Team:
Government Accountability Office: Homeland Security and Justice
Phone:
(202) 512-8757
GAO-11-17, FEMA Flood Maps: Some Standards and Processes in Place to Promote Map Accuracy and Outreach, but Opportunities Exist to Address Implementation Challenges
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United States Government Accountability Office:
GAO:
Report to Congressional Requesters:
December 2010:
FEMA Flood Maps:
Some Standards and Processes in Place to Promote Map Accuracy and
Outreach, but Opportunities Exist to Address Implementation Challenges:
GAO-11-17:
GAO Highlights:
Highlights of GAO-11-17, a report to congressional requesters.
Why GAO Did This Study:
The Federal Emergency Management Agency (FEMA), a component of the
Department of Homeland Security (DHS), maps flood hazard areas across
the country and makes flood insurance available to more than 20,100
communities through the National Flood Insurance Program. From 2003
through 2008, FEMA spent $1.2 billion in a comprehensive effort to
update the nation‘s flood insurance maps. In 2009, FEMA began an
annual review of 20 percent of the nation‘s flood maps, for which
Congress allocated $440 million in 2009 and 2010. As requested, GAO
reviewed the actions FEMA has taken to enhance the accuracy of updated
flood maps, and FEMA‘s outreach efforts in conducting flood mapping
activities. GAO analyzed FEMA‘s mapping standards and information
systems, tested quality assurance processes, and interviewed FEMA
officials and contractors.
What GAO Found:
FEMA has taken a number of steps to enhance the accuracy of flood
maps, but challenges related to implementing standards to ensure map
accuracy remain. Steps FEMA has taken include adopting a risk-based
method to prioritize mapping projects, implementing mapping standards
and guidance, establishing risk-based standards for topographic detail
to ensure that the highest risk areas have the most accurate
topographic data, and implementing quality control processes for
ensuring engineering data is collected and used in accordance with
standards. However, FEMA‘s mapping standards could be improved. For
example, FEMA has standards for determining the extent to which new
and updated flood mapping data are sufficiently current to promote map
accuracy, yet FEMA has not developed uniform guidance for the
validation of existing mapping data. Doing so could help FEMA both
track and report the accuracy of maps at the national and regional
levels and better assess mapping data needs. FEMA‘s quality control
process for ensuring the accuracy of flood maps could also be
improved. Audits of FEMA‘s mapping contractors‘ efforts have been
conducted since 2006 by an independent verification contractor;
however, FEMA officials said they planned to transfer responsibility
for the verification audits, part of its independent verification and
validation process, to its program management contractor by the end of
this year, who will then monitor FEMA‘s mapping contractors. The
transfer of these responsibilities creates a potential conflict of
interest because the program management contractor is to monitor the
results of its program management efforts. According to industry best
practices, verification and validation efforts should be independent
and reported directly to senior management to provide added assurance
that reported results on the project‘s status are unbiased. The
performance of the verification and validation function by an entity
that is technically, managerially, and financially independent of the
organization in charge of what it is assessing could better position
FEMA to help ensure the independence of the verification and
validation function, both in appearance and in fact.
FEMA has taken a variety of steps to conduct outreach to state and
local officials, including developing a national outreach strategy,
but could enhance its efforts to improve public awareness and promote
map acceptance. For example, FEMA has not developed performance goals
or measures, or identified the resources needed for its flood mapping
outreach efforts, which could help FEMA better determine whether its
outreach efforts are achieving their intended results. In addition,
FEMA could better quantify, allocate, and leverage resources needed to
support national outreach efforts. For example, by tracking spending
and using risk in its decisions for allocating outreach resources,
FEMA could better allocate resources for flood mapping outreach
efforts. In addition, FEMA could enhance its outreach efforts by
leveraging existing flood insurance marketing resources and expertise
during the mapping process to increase public acceptance of flood maps.
What GAO Recommends:
Among other things, GAO recommends that FEMA establish guidance for
validating data, transfer responsibility for verification audits to an
independent entity, and establish goals and measures for promoting
public acceptance of mapping. FEMA concurred with 10 of the 11
recommendations in this report, but disagreed with transferring
verification audit duties to an independent entity because it believes
its program management contractor is sufficiently independent. GAO
believes this recommendation remains valid as stated in this report.
View [hyperlink, http://www.gao.gov/products/GAO-11-17] or key
components. For more information, contact William O.Jenkins, Jr.,at
(202) 512-8757 or JenkinsWO@gao.gov.
[End of section]
Contents:
Letter:
Background:
FEMA Has Taken Steps to Enhance Flood Map Accuracy, but Faces
Challenges in Implementing Standards and Its Quality Assurance Process
for Program Management:
FEMA Has Taken Actions to Improve Outreach Efforts but Could Enhance
Its Efforts to Improve Awareness and Promote Map Acceptance:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objective, Scope, and Methodology:
Appendix II: Key Practices for Effective Communications to the General
Public:
Appendix III: Summary of Studies and Related Findings from 1997
through 2009:
Appendix IV: Comments from the Department of Homeland Security:
Appendix V: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Mapping Partners Roles and Activities in the Flood Map
Production Process:
Table 2: Historical Data Quality Issues and Recommendations in FEMA's
Flood-Mapping Efforts:
Figures:
Figure 1: Effects of Development on a Riverine Floodplain:
Figure 2: Riverine Floodplain Boundary and the Base Flood Elevation:
Figure 3: Map Production Process Overview:
Figure 4: FEMA's Map Process Steps and Map Accuracy Standards:
Figure 5: Light Detection and Ranging Technology Used to Generate
Digital Elevation Data:
Figure 6: Estimated Compliance Rates with FEMA Documentation
Regulations: Counties Having Flood Mapping Projects Since 2005 That
Resulted in a Change in Base Flood Elevation:
Figure 7: GAO Analyst Examining Files at FEMA's Engineering Library:
Figure 8: Overview of Outreach Steps in the Flood Mapping Process:
Abbreviations:
ASFPM: Association of State Floodplain Managers:
BFE: Base Flood Elevation:
CEO: Chief Executive Officer:
CTP: Cooperating Technical Partners:
DFIRM: Digital Flood Insurance Rate Map:
DHS: Department of Homeland Security:
FBS: Floodplain Boundary Standard:
FEDD: Flood Elevation Determination Docket:
FEMA: Federal Emergency Management Agency:
FIRM: Flood Insurance Rate Map:
FIS: Flood Insurance Study:
IV&V: Independent Verification and Validation:
LFD: Letter of Final Determination:
LIDAR: Light Detection and Ranging:
MIP: Mapping Information Platform:
NFIP: National Flood Insurance Program:
NVUE: New, Validated, or Updated Engineering:
PTS: Production and Technical Services:
QA/QC: Quality Assurance/Quality Control:
Risk MAP: Risk Mapping Assessment and Planning:
SFHA: Special Flood Hazard Area:
USGS: United States Geological Survey:
[End of section]
December 2, 2010:
The Honorable Sherrod Brown:
Chairman:
Subcommittee on Economic Policy:
Committee on Banking, Housing and Urban Affairs: United States Senate:
The Honorable Jeff Bingaman:
United States Senate:
The Honorable Charles E. Schumer:
United States Senate:
Unprecedented flooding in 2009 and 2010 in Atlanta, Georgia;
Nashville, Tennessee; Oklahoma City, Oklahoma; and in 24 counties
across Arkansas caused millions in property damages and heightened the
nation's awareness of the importance of flood insurance.[Footnote 1]
The Federal Emergency Management Agency (FEMA), a component of the
Department of Homeland Security (DHS), is responsible for mapping
flood-prone areas across the country. Based upon the estimated flood
risk reflected in these maps, FEMA makes flood insurance available to
property owners in more than 20,000 communities that participate in
the National Flood Insurance Program (NFIP). We designated the program
as a "high-risk" area in March 2006 because it likely will not
generate sufficient revenues to repay the billions it borrowed from
the Treasury to cover flood claims from the 2005 hurricanes.[Footnote
2] From 2003 through 2008, FEMA was appropriated $1.2 billion for a
comprehensive effort to update the nation's inventory of flood
insurance maps--known as the Map Modernization initiative. In fiscal
years 2009 and 2010, Congress appropriated a total of $440 million for
FEMA to continue its flood mapping efforts.[Footnote 3] Federal law
requires FEMA to assess the need to revise and update the nation's
flood maps at least every 5 years;[Footnote 4] in response, FEMA
reviews 20 percent of flood maps on an annual basis.[Footnote 5]
As FEMA concluded in an August 2010 report to Congress, inaccurate
maps create substantial difficulties by undermining confidence in the
NFIP, leaving some individuals and organizations unaware of their
risks, and imposing unnecessary costs on others whose risk is
overstated.[Footnote 6] FEMA established its 5-year Risk Mapping
Assessment and Planning (Risk MAP) program in 2009 to, among other
things, improve the quality of flood data used for mapping and enhance
public acceptance of flood maps.
Ensuring the accuracy--and promoting public acceptance of--flood maps
are ongoing challenges that FEMA faces in implementing its national
flood mapping program, as evidenced by past reviews and
recommendations made by us and others in assessing FEMA's efforts. For
example, in our 2004 report on FEMA's mapping program, we assessed
FEMA's plans to match the accuracy of flood data with communities'
relative flood risk and reported that FEMA had not yet established
data standards that describe the appropriate level of detail,
accuracy, and analysis required to develop digital maps based on risk
level.[Footnote 7] We recommended that FEMA develop and implement
flood-mapping data standards for data collection and analysis for
communities of similar risk. FEMA agreed and, in response, established
a risk-based standard for the accuracy of mapping floodplain
boundaries in 2005. In our report, we also reviewed FEMA's
partnerships with states and local entities that conduct mapping
activities and reported that FEMA had not yet developed a clear
strategy for partnering with communities with few resources and little
or no experience in flood mapping. We recommended that FEMA develop
and implement strategies for partnering with state and local
stakeholders and establish useful performance measures to assess its
progress in increasing stakeholders' awareness and use of new maps.
FEMA agreed and, in 2006, cited a number of activities the agency had
taken to increase the effectiveness of its mapping partnerships,
including the development and implementation of a national outreach
strategy and the creation of an outreach consortium to share lessons
learned. Recommendations to improve flood-mapping data quality and
community outreach have also been made by the Technical Mapping
Advisory Council,[Footnote 8] and by the Department of Homeland
Security's Office of Inspector General.[Footnote 9]
You requested that we review FEMA's flood mapping program. In
response, this report addresses the following objectives:
* To what extent has FEMA taken actions to enhance the accuracy of
flood maps, and what challenges, if any, does FEMA face?
* To what extent has FEMA taken actions to help promote community
acceptance of flood maps, and what challenges, if any, does FEMA face?
To address our first objective, we assessed FEMA's standards and
guidance against criteria in recent reports by the National Academies
of Sciences and the National Research Council.[Footnote 10] We
discussed the reports' methodologies with the authors and with
relevant FEMA officials, and analyzed reviews and critiques of the
Academies' reports to determine that they were appropriate for our
purposes. We analyzed information on FEMA's policies and plans for
flood map modernization, data from FEMA's Mapping Information Platform
(MIP) for the period of October 2005 through 2009, and systems for
documenting compliance with FEMA's data quality standards.[Footnote
11] To assess FEMA's internal controls and the reliability of computer-
processed flood map data, we examined FEMA databases, including the
MIP, which was designed to monitor the mapping process and the
completion of FEMA's quality assurance/quality control (QA/QC)
process. We tested the controls on the QA/QC process by extracting and
reviewing data on all projects initiated and completed from fiscal
years 2006 through 2009. We also analyzed FEMA's Floodplain Boundary
Standard (FBS) and New, Validated, or Updated Engineering (NVUE)
verification systems that were designed to track implementation of
data accuracy requirements. We tested the controls on the FBS and NVUE
compliance process by extracting and reviewing data on all projects
initiated and completed from fiscal year 2006 (when the FBS was
established) through 2009 and compared them against criteria in
Standards for Internal Control in the Federal Government.[Footnote 12]
To assess the reliability of these databases, we compared data to
FEMA's management reports, interviewed FEMA's three mapping
contractors, and analyzed the original data. We determined that the
FBS and NVUE compliance data were sufficiently reliable for our
purposes. We also discussed FEMA's mapping process and standards with
agency officials, as well as other federal stakeholders in geographic
data collection and mapping, including officials at the U.S.
Geological Survey, the National Oceanic and Atmospheric
Administration, the U.S. Army Corps of Engineers, and subject-matter
experts on flood hazards and floodplain management from national
organizations, including the Association of State Floodplain Managers
and the National Association of Flood & Stormwater Management
Agencies, which are stakeholders to FEMA's mapping initiatives. We
focused our review on FEMA's standards and processes related to flood
hazard mapping for rivers and streams (commonly know as "riverine"
flooding[Footnote 13]), which account for about 95 percent of FEMA's
flood maps, according to FEMA. As a result, we limited our scope to
exclude those standards and processes related to flood hazard mapping
for coastal areas and the levee certification. In addition, FEMA has
processes to modify and update flood map information during the time
that a community's maps are in effect, called a Letter of Map Change,
which is also outside the scope of our work.
To address our second objective, we analyzed information on FEMA's
policies, requirements for community outreach, and data from FEMA's
information management systems (discussed above) for documenting
compliance with statutory and regulatory requirements for documenting
coordination with state and local officials involved in mapping
projects. To determine FEMA's compliance with documentation
requirements, we examined FEMA's Flood Elevation Determination Dockets
(FEDD) files that are established for each mapping project. We
reviewed FEDD files from a probability sample of 88 counties from a
population of 431 counties that had completed studies from fiscal year
2006 through 2009 that resulted in a change in base flood elevation.
[Footnote 14] From this sample, we reviewed mapping partners'
compliance with six documentation requirements.[Footnote 15] In
addition, we analyzed the goals and performance measures of FEMA's
outreach strategy for Map Modernization, and its Risk MAP national
outreach strategy against prior GAO work reviewing federal agencies'
practices for development of national strategies,[Footnote 16] as well
as FEMA's budget and staff allocations related to outreach.
To supplement our analyses of FEMA's flood mapping internal controls
and program management activities related to data accuracy and
community outreach, we selected four flood map modernization projects
in Arizona, California, Florida, and North Carolina to visit. We
selected these locations based on our 2004 review to highlight
specific challenges associated with the mapping process, such as
inclusion of levees, and the impact of varying degrees of community
involvement and outreach in the 5 years since our review. The results
from these locations cannot be generalized to all flood map
modernization projects, but enabled us to describe challenges FEMA
faces in conducting its national flood mapping activities by talking
with relevant state and local officials. An expanded discussion of our
scope and methodology is described in appendix I.
We conducted this performance audit from August 2009 through December
2010, in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
Background:
FEMA is the primary federal agency responsible for assisting state and
local governments, private entities, and individuals to prepare for,
mitigate, respond to, and recover from natural disasters, including
floods. Floods are the most frequent natural disasters in the United
States, causing billions of dollars of damage annually. To address the
increasing amount of flood damage, the lack of readily available
insurance for property owners, and the cost to the taxpayer for flood-
related disaster relief, Congress passed the National Flood Insurance
Act of 1968, which created the NFIP.[Footnote 17] Since its inception,
the NFIP has served as a key component of FEMA's efforts to minimize
or mitigate the damage and financial impact of floods on the public,
as well as to limit federal expenditures needed after floods occur.
The NFIP seeks to minimize flood-related property losses by making
flood insurance available on reasonable terms and encouraging its
purchase by people who need flood insurance protection--particularly
those living in the areas at highest risk of flooding, known as
Special Flood Hazard Areas, designating a 1 percent annual chance of
flooding. To do so, FEMA along with its state and local partners,
identifies and maps flood-prone areas in the more than 20,100
communities that currently participate in the program.[Footnote 18]
When the NFIP was created, the purchase of flood insurance was
voluntary. Congress amended the original law in 1973 to require the
purchase of flood insurance in certain circumstances. The purchase of
flood insurance is required for structures in Special Flood Hazard
Areas of communities participating in the program if (1) any federal
loans or grants were used to acquire or build the structures or (2)
the structures have outstanding mortgage loans made by lending
institutions that are regulated by the federal government. Property
owners located in the Special Flood Hazard Area with mortgages from
federally regulated lenders are required to purchase and maintain
flood insurance policies.
FEMA identifies flood hazards, assesses flood risks, and provides
appropriate flood hazard and risk information to communities
nationwide. To identify hazards and assess risks, mapping projects are
performed in accordance with FEMA Guidelines and Specifications. Flood
maps provide the basis for setting insurance rates and identifying
properties whose owners are required to purchase flood insurance.
FEMA's flood hazard maps are also used by lending institutions to
determine who is required to purchase flood insurance and help ensure
that flood insurance is purchased and maintained for these properties.
Local government planning and zoning officials, land developers, and
engineers use the maps for developing zoning regulations and designing
new buildings and infrastructure to be safe from flooding. FEMA has
estimated that local governments' compliance with the program's
standards for new construction saves over $1 billion annually in flood
damage avoided.
Stakeholders from All Levels of Government and the Private Sector
Participate in the Mapping Process:
FEMA's Federal Insurance and Mitigation Administration, which manages
the NFIP, is comprised of three divisions: Risk Analysis, Risk
Reduction, and Risk Insurance.[Footnote 19] The Risk Analysis Division
is responsible for flood mapping activities and develops flood mapping
policy and guidance. FEMA's 10 Regional offices manage flood map
production for their geographic areas. FEMA headquarters and regional
staff monitor and report flood hazard mapping progress based on
program management data provided by flood mapping partners.
Mapping partners can include FEMA's 3 national Production and
Technical Services (PTS) contractors, as well as state and local
governments or regional agencies--including those state and local
governments that are participating in FEMA's Cooperating Technical
Partners (CTP) program. The PTS contractors are private engineering
firms working under contract to FEMA and are each responsible for a
regional portfolio of flood study projects. Table 1 summarizes the
roles and responsibilities of FEMA, the mapping partners, and other
actors in the flood map production process.
Table 1: Mapping Partners Roles and Activities in the Flood Map
Production Process:
Stakeholders: FEMA headquarters staff; Requirement or responsibility
or role:
* Manage national flood-mapping program;
* Monitor local governments' adoption of maps and updates to
ordinances.
Stakeholders: FEMA regional staff;
Requirement or responsibility or role:
* Oversee scoping meeting between all mapping partners;
* Manage flood-mapping process;
* Lead meetings to present preliminary maps with local government
officials;
* Provide local government officials with outreach tools;
* Attend public meetings.
Stakeholders: Mapping partners:
* Contractors;
* Cooperating Technical Partners (CTPs);
* Other federal agencies[A];
Requirement or responsibility or role:
* Assist in scoping meeting;
* Collect required data or validates existing data; Assist FEMA in
administering flood-mapping activities (see text above);
* Analyze flood hazard data sources (i.e. climate, stream flow, soil,
land use, elevation, hydraulic structure);
* Produce flood hazard estimates;
* Implement quality controls;
* Create preliminary maps;
* Attend public meetings;
* Resolve appeals and/or protests to preliminary maps;
* Create final maps.
Stakeholders: State & local officials[B]; Requirement or
responsibility or role:
* Participate in scoping meeting;
* Identify data assets and needs during scoping meetings;
* Provide feedback on preliminary maps;
* May conduct outreach to individuals in the community;
* Collect appeals and/or protests to the preliminary maps from
individuals and forwards to FEMA;
* Update local governments' floodplain ordinances.
Stakeholders: Community/general public (e.g., property owners,
businesses, local real estate industry, etc.); Requirement or
responsibility or role:
* Attend public meetings;
* Provide feedback on preliminary maps;
* May file challenges--appeals and/or protests--to preliminary maps.
Source: GAO analysis of FEMA data.
[A] Other Federal agencies who work under interagency agreements with
FEMA could include, for example, the U.S. Army Corps of Engineers,
Natural Resources Conservation Service, U.S. Geological Survey,
National Oceanic and Atmospheric Administration, and the Tennessee
Valley Authority.
[B] State and local officials can also be Cooperating Technical
Partners.
[End of table]
FEMA relies on local governments to provide it with notification of
changing flood hazard information and to work with FEMA to collect the
information needed to reflect the updated flood hazards on the flood
maps. Changes to communities such as new development can affect
floodplain boundaries, as shown in figure 1 below. Thus, as we noted
in our 2004 report, the ultimate success of FEMA's flood mapping
program depends on the level of community investment and involvement
in the process.[Footnote 20]
Figure 1: Effects of Development on a Riverine Floodplain:
[Refer to PDF for image: illustration]
The illustration depicts before and after development, including re-
grading/filling and subsequent flooding.
Sources: GAO analysis of FEMA data; and Art Explosion clipart.
[End of figure]
A community's flood hazard maps can be updated in response to a FEMA-
initiated study or revised study of flood hazards and subsequent
revision of NFIP flood maps or through a community-initiated revision.
Each year, FEMA revises existing maps in communities across the
nation. Because of funding constraints, FEMA can study or revise maps
for only a limited number of communities each year. As a result, FEMA
prioritizes new and revised study needs based on a cost-benefit
approach whereby the highest priority is given to studies where
development is greatest and where the maps are most outdated.
Overview of Flood Mapping Production Process:
[Side bar:
Topographic Accuracy:
Topographic accuracy is a function of detail and age. Detail is
important because detailed topography has significantly fewer errors
than less detailed alternatives and better accounts for hydraulic
structures”structures that affect water flow”such as buildings, dykes,
river banks, and roads. Age is important because topography can change
over time due to development and ecological factors such as erosion.
The topographic data used in mapping studies can have significant
variances in age and detail, and thus, accuracy. Source: GAO analysis.
End of side bar]
[Side bar:
Base flood elevation (BFE):
The computed elevation of a flood having a 1 percent chance of being
equaled or exceeded in a given year is the base flood elevation. It
accounts for the volume and velocity of water moving through the
watershed and reflects the cumulative effects of topography, soils,
vegetation, surface permeability, and other factors. The BFE is the
regulatory standard for the elevation or flood proofing of structures,
and the relationship between the BFE and the elevation of a structure
also determines the flood insurance premium. In general, the higher
the first floor elevation, the lower the insurance premium.
Consequently, the accuracy of BFEs on the flood maps is important for
both regulating and insuring properties commensurate with the risk of
flooding. Source: National Academies of Science. End of side bar]
Flood mapping is a complex and technical endeavor. In order to create
a map, engineers must conduct field surveys to assess the area to be
studied and then develop data on the elevation of the terrain--called
topographic data.[Footnote 21] Engineers develop flood hazard data
that estimates the risk of flooding by performing analyses on the
hydrologic conditions that affect the amount of water that flows
downstream during a flood (for example, soil and vegetation absorb
rain and reduce runoff while pavement and other impermeable manmade
surfaces increase the flow of runoff) and the hydraulic conditions
that affect the height of floodwaters in streams or waterways (for
example, bridges may create narrower channels that raise the water
level as it passes under the bridge).
The results of the analyses of these different types of topographic
and flood hazard engineering data are then combined and integrated
into digital maps that describe how far (the floodplain boundary) and
how high floodwaters will reach (the Base Flood Elevations, or BFEs) --
as shown in figure 2 below. Each step in the process contributes to
the ultimate accuracy of the final map but also requires judgment and
involves uncertainty. Without a long and well-documented record of
flooding in a floodplain, the precision of flood hazard information is
difficult to determine. Because weather predictions and land use are
difficult to predict, the correctness of the flood maps cannot be
determined with certainty. Instead, the maps must be evaluated based
on a relative correctness or general reliability of the flood maps and
flood insurance study. Some of the factors that impact reliability of
the study are the type of topographic data used, the hydrologic and
hydraulic models used and the assumptions computed, and the final
mapping techniques by the mapping partners.
Figure 2: Riverine Floodplain Boundary and the Base Flood Elevation:
[Refer to PDF for image: illustration]
The illustration depicts the following:
* normal channel;
* Base Flood Elevation (BFE);
* Special Flood Hazard Area.
Sources: GAO analysis of FEMA data; and Art Explosion clipart.
[End of figure]
Through various stages of the mapping production process, FEMA, in
consultation with mapping partners and localities, determines the
flood map study's level of accuracy and precision. In making this
decision, required costs and resources, budget priorities, and
communities' flood hazard identification needs are considered. An
overview of the mapping production process is provided in figure 3
below. This determination affects the study's cost and the resulting
flood map's accuracy. Detailed flood studies incorporate greater
amounts of data or more precise data into a map to provide greater
granularity of information, for example, by determining BFEs within a
Special Flood Hazard Area, to reduce uncertainty. In contrast,
approximate flood studies generally require less precision in flood
hazard data. For example, they are used for areas that are less
subject to development and do not require the establishment of a
regulatory base flood elevation, although base flood elevations may be
identified on the flood map based on an agreement between FEMA, its
mapping partners, and state and local governments. Even when
floodplains are mapped with high accuracy, land development and
natural changes to the landscape or hydrologic systems create the need
for continuous map maintenance and updates.
Figure 3: Map Production Process Overview:
[Refer to PDF for image: illustration]
(A) Local Needs Identified: 1–6 months; Multi-Year flood hazard
identification; Scoping.
(B) Data Development Period: 12-24 months; Engineering & Mapping data:
Topographic, Hydrology, Hydraulics; Preliminary maps;
Community review: 30-day period.
(C) Regulatory Adoption Period: 6-9 months; Appeal;
Map adoption.
(D) Map maintenance begins.
Sources: GAO analysis of FEMA data.
Key:
A - Local needs identified - FEMA, mapping partner, and local
government officials meet to discuss a plan and schedule a Scoping
Meeting(s) for flood mapping project, including data needs.
B - Data Development period - Mapping partner collects data or
validates existing data and uses a model to create preliminary maps.
All maps inevitably contain some uncertainty because of technological
limitations and budgetary constraints. Preliminary maps are presented
to local government officials to identify issues. FEMA publishes
notifications of new flood maps in the Federal Register and twice in
the local newspaper. Local officials may decide to hold public
meetings.
C - Regulatory Adoption Period:
Appeal Period - 90-day period for local government officials or
individuals to challenge the preliminary maps as scientifically or
technically inaccurate because they include, for example, inaccurate
flood levels, flood boundaries not matching elevation of terrain,
incorrect street names, city limits, etc. - After all appeals are
resolved, FEMA sends a Letter of Final Determination (LFD) to the
community CEO to say the maps are now "final."
Adoption Period - After maps are final the local government must
update its ordinances within 6 months. If the local government does
not update its ordinances, it could be suspended from the National
Flood Insurance Program.
D - Map Maintenance - After maps are final, the local government or
individuals can file a "Letter" to modify or update an individual
property or parcels of land within the flood maps for reasons such as
new development, mitigation efforts, or the limitation of map scale
and the collection of more accurate ground elevations data on a given
property. In addition, map maintenance also includes re-analysis and
revision of maps - not by letter, but by republishing the entire map -
based either on information provided by local government or by FEMA's
identification of an update need.
[End of figure]
The National Flood Insurance Act of 1968, as amended, and federal
regulations require that FEMA communicate potential changes in flood
risk to the public when it decides to initiate a flood mapping study
and when it is ready to release preliminary maps. At the beginning of
the mapping process, FEMA is required to notify local governments.
[Footnote 23] When FEMA is ready to release preliminary maps, the
agency must publish the proposed base flood elevations in the Federal
Register for public comment and notify the local government of the
results of the study.[Footnote 24] When the final map is approved,
FEMA publishes another Federal Register notice.[Footnote 25] FEMA is
required to maintain documentation of selected elements of its public
notification efforts.[Footnote 26] Outside of these statutory and
regulatory requirements, FEMA has historically focused its outreach
efforts on local government officials and has relied on local
officials to inform the community at large (i.e., the public) of flood
mapping efforts.[Footnote 27]
Map Modernization to Risk MAP:
Traditionally, flood maps were created and stored in paper format. In
the early 1990s, however, some of the data and information FEMA
collected to develop flood maps started becoming available in digital
format. In 1997, FEMA developed its initial flood Map Modernization
plan that outlined the steps necessary to update the nation's flood
maps to digital format and streamline FEMA's operations in raising
public awareness of the importance of the maps and responding to
requests to revise them. FEMA's initial flood Map Modernization plan
was to fully digitize all flood maps in the nation, first, by
identifying those maps that required engineering updates and
converting them to a digital format. FEMA's initial goal was to
convert approximately 80 percent of existing paper maps to a digital
format, update 20 percent of the existing maps with new flood risk
information while converting them to digital format, and add 13,700
completely new maps (also in digital format) to cover previously
unmapped communities. Then, a planned maintenance phase would follow
the Map Modernization initiative, whereby these maps would be updated
with new engineering data.
In March 2006, FEMA performed a mid-program evaluation that considered
input from our prior work, as well as the Congress, the Department of
Homeland Security's Inspector General, and other stakeholders. As a
result, FEMA instituted a mid-course adjustment of the Map
Modernization's program goals and objectives. FEMA's modified
objectives for the initiative were to (1) produce new digital
products; (2) provide new, updated, or validated engineering analyses;
and (3) integrate a new Floodplain Boundary Standard into the digital
maps. As part of this mid-course adjustment, FEMA ranked all 3,146
counties in the United States in terms of flood risk 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 its mapping priorities that the
agency used to schedule mapping projects during the course of its Map
Modernization initiative, which FEMA detailed in their Multi-Year
Flood Hazard Identification Plans. From fiscal years 2003 through
2008, FEMA spent $1.2 billion for flood map modernization. FEMA
initiated the final year of production under Map Modernization in
2008. [Footnote 28]
In fiscal year 2009, FEMA began a 5-year effort--Risk MAP--with $300
million in funding from the National Flood Insurance Fund and
congressional appropriations for flood hazard mapping. According to
FEMA, the vision for Risk MAP is to deliver quality data that
increases public awareness and leads to action that reduces risk to
life and property. According to FEMA's Risk MAP, Quality Assurance
Management Plan, quality data is defined as accurate, credible,
timely, and efficiently delivered.
FEMA Has Taken Steps to Enhance Flood Map Accuracy, but Faces
Challenges in Implementing Standards and Its Quality Assurance Process
for Program Management:
FEMA Has Developed Standards and a Quality Assurance Process to
Enhance Map Accuracy:
FEMA has implemented and tracks compliance with three standards for
ensuring the quality of data used in developing flood maps: FEMA's
Guidelines and Specifications; the Floodplain Boundary Standard (FBS),
and 2 of the 3 elements of the New, Validated and Updated Engineering
(NVUE) data standard.
* Guidelines and Specifications for Flood Hazard Mapping Partners--
FEMA established the Guidelines and Specifications to define technical
requirements, product specifications for Flood Hazard Maps and related
NFIP products, and associated coordination and documentation
activities. In addition, FEMA periodically amends the Guidelines and
Specifications, through Procedural Memoranda. For example, in
September 2010, FEMA revised Guidelines and Specifications for
acquiring elevation to include risk-based standards for gathering and
using topographic data.
* Floodplain Boundary Standard--In response to stakeholders concern
about the quality of flood data used to develop new flood maps during
the Flood Map Modernization program, FEMA issued the FBS in October
2007, in part, to help ensure that flood maps are tied to a
topographic source. The purpose of the FBS is to ensure the locations
of the predicted horizontal (floodplain boundary) and vertical (base
flood elevation) lines drawn on flood maps are comparable to the
topographic data that has been selected for the study area. For
example, maps showing water running uphill could occur if inaccuracies
existed when calculating the base flood elevation against the
topographic data, according to mapping contractors. The FBS reduces
the chance of such errors taking place, which enhances the public
credibility of flood maps, according to mapping contractors. All
studies contracted since 2006 must comply with the FBS. In FEMA's 2006
Mid-Course Adjustment to the Map Modernization program, the agency set
a goal that 75 percent of stream miles reflected on FEMA's issued maps
were to be compliant with FBS by the end of Map Modernization.
[Footnote 29] FEMA's last quarterly report of fiscal year 2009
indicated that FEMA had met this goal; according to the report, flood
maps have reached approximately 89 percent stream mile compliance with
the FBS nationally.
* New, Validated, or Updated Engineering (NVUE) standard--FEMA also
developed a standard called the New, Validated, or Updated Engineering
(NVUE) standard to provide a basis for assessing the engineering
analysis used to develop flood elevations. FEMA developed the standard
to help mapping partners determine where new study data should be
collected, where updates to existing flood hazard data should be
performed, and whether previously developed flood study data could
still be considered valid. FEMA issued draft guidance for validating
existing data in April 2007. FEMA intends to use the NVUE data quality
standard in implementing its Coordinated Needs Management System.
According to officials, the Coordinated Needs Management System is an
assessment tool to determine mapping needs and a means for making
funding allocation decisions. FEMA officials stated that the
Coordinated Needs Management System is to provide FEMA with a national
assessment of data needs. However, the system is under development and
is projected to be implemented nationwide in 2011. According to FEMA
officials, the Coordinated Needs Management System is to track
information including the flood zone designation, risk assigned, study
type, and the date the analysis was completed or validated. FEMA
believes that this approach will provide better detail regarding the
precision of a flood hazard analysis for end users that they can
understand, and will be applied in a risk-based manner.
To monitor the quality of the process used throughout development of
flood maps in accordance with the standards in the Guidelines and
Specifications, FEMA established the Mapping Information Platform
(MIP) information system. The MIP provides mapping partners the tools
and technology to create, validate, store, track and update flood data
according to FEMA's standards using the MIP's map production
processes. FEMA also developed quality assurance management plans and
processes to work with local communities and flood mapping partners.
FEMA's quality management plans identify quality assurance steps that
are to occur during the creation, review, and editing of flood hazard
study. On December 1, 2008, FEMA issued revised guidance for seven
quality control reviews to be performed during the flood map
production process. Figure 4 below provides an overview of FEMA's
three data quality standards and the quality assurance process in the
context of the steps in the mapping process.
Figure 4: FEMA's Map Process Steps and Map Accuracy Standards:
[Refer to PDF for image: illustration]
(A) Local Needs Identified: 1–6 months; Multi-Year flood hazard
identification; Scoping.
(B) Data Development Period: 12-24 months; Engineering & Mapping data:
Topographic, Hydrology, Hydraulics; Preliminary maps: Floodplain
Boundary Standard (FBS); NVUE Compliance Standard;
Community review: 30-day period.
’Guidelines and Specifications“ compliance for new data is applied
from Scoping through Map Maintenance.
(C) Regulatory Adoption Period: 6-9 months; Appeal;
Map adoption.
(D) Map maintenance begins.
Sources: GAO analysis of FEMA data.
[End of figure]
In addition, FEMA established a quality assurance management system
under both their Map Modernization and Risk MAP efforts to ensure that
mapping products and processes comply with FEMA's specified
requirements. Included in FEMA's quality assurance system are audits
of the mapping process by Independent Verification and Validation
(IV&V) audits. The IV&V contractor is to independently provide
feedback to FEMA as part of the audit, such as sampling it conducted
on the results of mapping projects performed by mapping partners. We
previously reported that world-class, private sector corporations
successfully employ best practices with quality assurance by using
process controls to design products and by controlling production
processes as the production is occurring.[Footnote 30] FEMA's quality
management system and quality assurance process reflects the
recognized best practice of reviewing the quality of the map product
during the production process.
FEMA Enhanced Its Guidelines for Topographic Data by Establishing Risk-
Based Standards:
FEMA has recently published a quality standard to set a minimum level
of topographic detail for all studies in its Guidelines and
Specification. Specifically, it established standards for the level of
topographic detail required to ensure that the maps of those areas at
the highest risk from flooding have the most accurate topographic
data, as suggested by the National Research Council and FEMA's Risk
MAP strategy. In September 2010, FEMA published Procedural Memorandum
61 to update its Guidelines and Specifications requiring mapping
partners to align FEMA's topographic data specifications to levels of
risk for flooding, as well as account for differing characteristics of
elevation that can affect the accuracy and precision of base flood
elevations. This procedural memorandum identifies the specifications
of elevation accuracy and precision needed based on FEMA's previously-
identified risk classes for all 3,146 counties in the United States.
As the National Academies of Sciences report stated, the level of
detail used in a study should correspond to the area's risk. FEMA
officials stated that they will only be starting new studies in areas
where there are already existing updated and accurate topographic data
or in areas that have sufficient need and risk to necessitate FEMA's
funding the acquisition of such data.
Prior to the issuance of Procedural Memorandum 61 in September 2010,
FEMA delineated floodplains using the "best available" existing
topographic data for the area being studied. In the absence of data
provided by the mapping stakeholder or newly developed for a flood
mapping project, a primary source for topographic data was the
National Elevation Dataset maintained by the U.S. Geological Survey
(USGS),[Footnote 31] which is over 35 years old on average. FEMA's
existing standards for new topographic data required data that is
about 10 times more accurate than USGS topographic data and required
topographic data acquired or reviewed within the last 7 years to
account for changes such as human development. FEMA plans to work with
local officials to determine whether the existing data held by the
locality or another source (such as the USGS), meets new the new
standards, or to develop new data through means such as Light
Detection and Ranging (LIDAR). As illustrated in figure 5 below and as
we reported in 2004, FEMA has promoted the use of LIDAR remote sensing
technologies to generate highly accurate, digital elevation data. The
illustration shows an airplane equipped with laser-pulsing sensors
using LIDAR to gather digital elevation data to measure the contours
and crevices that determine where floodwaters collect. 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 that LIDAR will be the primary technology used
to acquire new digital elevation data for Risk MAP.
Figure 5: Light Detection and Ranging Technology Used to Generate
Digital Elevation Data:
[Refer to PDF for image: illustration]
The illustration depicts LIDAR Laser scanner interaction with the
countryside.
Sources: GAO analysis of FEMA data.
[End of figure]
In a study commissioned by FEMA and issued in 2009, the National
Academies of Sciences compared the effect of using USGS data versus
LIDAR data at three geographic locations using the same hydrologic and
hydraulic models. For each area studied, the two different sources of
topographic data resulted in different BFEs and floodplain boundary
locations. The report concluded that the quality of topographic data
is the most important factor in determining water surface elevations,
base flood elevations, and the extent of flooding and, thus, the
accuracy of flood maps for riverine areas, which account for
approximately 95 percent of FEMA's flood maps. FEMA officials agreed
that accurate data are essential and that even the best models cannot
produce an accurate flood map with inaccurate inputs, but they said
there is a point of diminishing returns where the cost of developing
highly accurate topographic data outweighs its overall benefit.
Prior to fiscal year 2010, FEMA did not generally provide funding for
mapping partners to acquire new topographic data in an effort to
conserve resources and share responsibilities, according to FEMA
officials.[Footnote 32] Historically, studies at all risk levels could
have used the USGS National Elevation Dataset as the best available
data, if obtaining better quality data was unaffordable, according to
FEMA officials. Officials from the Association of State Floodplain
Managers agreed with this characterization of historical mapping
efforts and said that cost constraints limit local governments and
mapping partners' ability to collect extensive data, a situation that
has resulted, in some cases, in poor map quality. FEMA officials
acknowledged that affordability issues have been the main reason high
risk areas may rely on USGS data for their study. To address this
issue, FEMA officials said they planned to provide $80 million in
funding in fiscal years 2010 through 2013 to acquire new topographic
data.
FEMA's Existing Data Quality Standards Could Be Better Implemented to
Match Mapping Data Precision with the Level of Flood Risk:
FEMA's Floodplain Boundary Standard (FBS) reporting does not reflect
the quality of topographic data or level of study detail, and
according to FEMA officials, 1 of the 3 elements of the standard for
New, Validated, and Updated Engineering (NVUE) data has not been fully
implemented.
The Floodplain Boundary Standard Could More Effectively Measure Map
Accuracy:
The accuracy of a map's floodplain boundary, in applying the FBS for
an area, is dependent on two factors--the quality of topographic data
and the level of detail used for a flood study. However, the method
FEMA uses in measuring FBS compliance does not account for these
factors when reporting FBS compliance rates for counties. Thus, two
maps using topographical data of widely varying accuracy and currency,
and based on studies of different levels of detail, can both be
considered FBS compliant as long as the base flood elevation and
floodplain boundaries are consistent with the topographic data used in
each study. Consequently, FBS compliance rates across counties do not
provide a means for FEMA management to compare the relative accuracy
of maps. According to FEMA, the FBS was created to address problems
that arose when existing paper map floodplain boundaries were
transferred to digital format; the purpose was to ensure that mapping
partners checked or revised preliminary maps to confirm they were
consistent with available topographic data, not to compare map
accuracy. The FBS, which is designed to help ensure the accuracy of
floodplain delineations, is an important FEMA measure of the quality
of flood maps. This is because individuals living within the
floodplain boundary are considered to be in a Special Flood Hazard
Area and are thereby required to purchase flood insurance while those
outside of the boundary are exempt from this requirement.[Footnote 33]
Stakeholders involved with the four mapping projects we contacted said
that the quality of FBS as a measure of accuracy is only as good as
the quality of the topographic data that measures land elevation.
Because FEMA's standard has historically been that the mapping
stakeholders should use the best available topographic data, the
quality (including precision) of the topographical data used to match
up with the floodplain boundary may vary widely depending upon the
quality of what is available.
The level of detail used in a flood study determines the requirements
necessary for a map to achieve FBS compliance. Detailed studies have
compliance standards more stringent than approximate studies that use
less accurate, often outdated topographic information and models,
according to the National Academies of Sciences report. According to
FEMA, the determining factors when deciding whether to perform
detailed or approximate studies for communities are the level of flood
risk in the area, the likelihood of additional development, and the
cost and benefits of performing a detailed study versus an approximate
study, as detailed studies are significantly more expensive than
approximate studies. Though FEMA advises against it, some communities
in the highest risk class have chosen to undergo approximate studies
due to fiscal restraints.
Differences in the level of detail used in studies leads to
significant variances in how precisely base flood elevations must
match the elevation data used to comply with the FBS. The BFEs in
detailed studies are required to be much more precise than those in
approximate studies, but each are considered to be equally compliant
as long as they meet the standards for their respective level of
detail. For example, the BFE in detailed studies are required to match
the topographic data within 1 foot, while BFEs in approximate studies
can differ from the topographic data used by up to 20 feet and be
considered compliant with FBS.[Footnote 34] For the purpose of
reporting whether FEMA has met its goal for the percentage of maps
that are FBS compliant, a compliant detailed study counts equally with
a compliant approximate study, with no consideration for the differing
requirements necessary to achieve this compliance.
In 2003, we identified linkage and clarity of measures as two key
attributes of successful performance measures.[Footnote 35]
Establishing separate measures of compliance for detailed and
approximate studies could allow FEMA to better use FBS compliance
rates as a measure of map accuracy; however, the data necessary to
accomplish this are presently not maintained by the agency. FEMA
officials said that these data were not tracked at a national level
because the significant increase in mapping activities associated with
Map Modernization focused agency efforts on map production rather than
data collection and analysis. FEMA officials acknowledged that the
agency lacked a way to systematically track, at a national level, the
types of topographic data or level of project detail used in each
study, which limited their ability to effectively and comprehensively
describe the accuracy of flood maps. Officials also stated that they
did not consider the need to use data on FBS compliance rates for
management decisions on map accuracy, as they believe that national
reporting of differences in the level of detail used in studies does
not provide significant insight into the flood data accuracy or
reliability. Nonetheless, we continue to believe that FBS compliance
rates reported for detailed and approximate studies within and across
counties could provide information that would both enable FEMA
management to compare the relative accuracy of maps, and be a more
meaningful and understandable measure to FEMA's mapping stakeholders
and the general public.
While FEMA does not track this information at a national level,
topographic data and other information regarding study detail,
referred to as metadata, are recorded at the individual mapping
project level within the MIP.[Footnote 36] As part of its Quality
Assurance process, FEMA requires mapping partners to submit metadata
within the MIP for review. FEMA checks the information to ensure its
validity and informs the mapping contractor if there are any problems
that may affect map accuracy. FEMA reviews this metadata, but the
agency does not retain or store the metadata in a way that enables
future analysis across all mapping studies that could support the
management of the mapping program. Standards for Internal Control in
the Federal Government provides that agencies should identify, capture
and distribute pertinent information in order to effectively carry out
the agencies' duties.[Footnote 37] While there is a cost associated
with retaining and analyzing metadata, FEMA could minimize these costs
by utilizing its existing technology, the MIP, to retain or store
these data in a way that enables future analysis across all mapping
studies. By doing so, FEMA could report additional information on FBS
compliance and, thereby, have a potentially better measure of map
accuracy. FEMA could then use this data to develop separate measures
of FBS compliance for both detailed and approximate flood studies,
each of which has a different range of accuracy.
FEMA Could More Fully Implement Its New, Validated, and Updated
Engineering Standard:
FEMA implemented its NVUE standard in 2007 to provide a basis for
flood mapping partners to assess the quality of new, validated, or
updated engineering data in revising maps, but has not fully developed
uniform guidance for the validation of existing data. Validation
guidance for mapping partners has existed in draft form since 2007,
but it has not yet been used, according to FEMA officials. This
guidance consists of a set list of parameters that define whether data
used in the past is adequate for current use, or whether the area
being studied has changed to an extent that new data is necessary.
FEMA's draft guidance on how to validate data was found to be
ineffective due to differing interpretations and methodologies used by
various mapping contractors, according to FEMA officials and FEMA
contractors who oversaw NVUE data collection and internal controls
during the Map Modernization effort. Prior to its being found
ineffective, contractors used this guidance, issued in the form of
checklists, to determine if enough changes had occurred in the area
being studied to render existing study data invalid. However, two
regions submitted validation figures to FEMA, each of which used a
different methodology to obtain their calculations. According to FEMA,
the agency determined that this process was too inconsistent to be
acceptable as a data quality standard, so validation of existing data
was discontinued until uniform guidance could be developed in 2011,
leaving only new and updated data counting as NVUE compliant.
As a result of the mid-course adjustment in 2006, FEMA set a goal of
reaching an NVUE compliance rate of 30 percent, meaning 30 percent of
the nation's stream miles would be mapped using new or updated
engineering analysis by the end of Map Modernization. The goal under
Risk MAP is to increase NVUE compliance to 80 percent to reflect this
phase's heightened focus on ensuring data accuracy. In January 2010,
FEMA reported the current rate of national NVUE compliance was 52
percent. Validating existing data could assist FEMA in reaching this
compliance goal. According to the NVUE standard, it is necessary to
determine the relative accuracy of flood hazard data on a community's
maps before a new mapping process begins, therefore, a needs
assessment must be conducted to determine whether existing flood
hazard information represents current conditions and is deemed valid
or current. In an August 2010 report to Congress, the agency
acknowledged that its Risk MAP strategy relies on validating the
currency of a substantial portion of existing flood hazard
information. FEMA officials said the development of a final version of
this guidance had been a secondary focus as the agency was focusing
its Map Modernization program resources on conversion of flood maps to
digital format and updating the most significant engineering needs.
Now that the initial map modernization program has been completed and
FEMA is implementing its Risk MAP strategy, complete guidance for
mapping stakeholders would be an effective and timely step to further
implement its new program.[Footnote 38] While FEMA believes that a
substantial portion of existing flood hazard information is still
current in those areas where development has not been significant,
establishing uniform guidance for the validation of existing data
could help FEMA ensure mapping partners are consistently validating
data, and thereby help FEMA both track and report the accuracy of maps
at the national and regional levels and better assess mapping data
needs.
FEMA's Independent Verification and Validation Process Helps Ensure
Maps Meet Minimum Requirements, but the Process Could Be Improved to
Better Ensure Compliance and Data Reliability:
FEMA has developed a quality assurance process to help ensure that
mapping efforts are performed in accordance with minimum data quality
standards, procedures, and requirements, including independent
verification and validation (IV&V) audits of a sample of FEMA's
completed mapping projects. However, we identified problems with this
process, which could impede FEMA's ability to ensure mapping efforts
are performed in accordance with requirements in FEMA's Guidelines &
Specifications. The use of verification and validation is a recognized
key practice for large and complex system development and acquisition
projects. The purpose of the verification and validation function is
to provide management with objective insight into the program's
processes and associated work products. For example, IV&V audits can
help FEMA identify problems related to compliance with data quality
standards. However, the number of flood studies selected annually for
IV&V is not based on probability sampling that would allow the results
of the audits to be generalized to a larger population and used for
quality assurance purposes. In addition, FEMA officials said the
agency planned to transfer responsibility for the IV&V process to its
program management contractor. However, the transfer of the
responsibilities could create a potential conflict of interest because
the program management contractor will be monitoring the results of
its own program management efforts. Finally, the manner in which
problems related to compliance with data quality standards has been
documented in IV&V audit reports does not facilitate systematic
analysis that could further enhance quality management efforts.
IV&V Is Not Based on Probability Sampling:
According to the IV&V auditor, its monthly reviews were based on a
nonprobability sample of map studies and it did not take steps to
ensure that the audit results would be generalizable to the entire
population of map studies. Specifically, FEMA officials told us that
although the IV&V contractor reported in its April 2010 report
[Footnote 39] that map products are frequently not meeting FEMA's
Guidelines and Specifications, FEMA regards these as minor issues in
the agency's overall quality assurance framework because the IV&V
contractor based their conclusions on a small sample of map studies
(i.e., a nonprobability sample). The major limitation of
nonprobability sampling is that the results cannot be generalized to a
larger population, because some members of the population being
studied have no chance or an unknown chance of being selected as part
of the sample. However, if FEMA's IV&V auditor used probability
sampling, FEMA program officials would have been better positioned to
know whether the audit issues were isolated events or indicative of
more systemic issues in its flood mapping efforts.
We recognize that conducting probability samples of map studies could
involve additional costs. However, not conducting IV&V audits on a
generalizable sample could also be costly. This is because using a
generalizable sample could better position FEMA to identify and
resolve systemic issues in flood mapping efforts, which is a critical
task in helping to ensure that future efforts are performed in
accordance with FEMA's standards and quality assurance management
plans. FEMA officials stated that the terms of work for a new IV&V
audit contractor had not yet been finalized and that while the
officials had not determined whether the benefits outweigh the costs
of conducting probability samples, they felt that reviewing the
results from probability samples would be beneficial. Implementing
probability samples in its IV&V audit process, to the extent that the
benefits outweigh the costs, could help FEMA management use the
results from its IV&V auditing process more strategically.
Transfer of IV&V Responsibilities to Program Management Contractor
Creates Potential Conflict of Interest:
Audits of FEMA's mapping contractors' efforts have been conducted
since 2006 by an independent verification contractor; however, FEMA
officials said they planned to transfer responsibility for the IV&V
process to its program management contractor by the end of this year,
which will then monitor the FEMA's mapping contractors. The transfer
of these responsibilities creates a potential conflict of interest
because the program management contractor is to monitor the results of
its program management efforts. FEMA officials said they integrated
the verification and validation process into its program management
contract because the current IV&V contract was expiring and they
believed that using FEMA's program management contractor for the
product quality management would be the most effective and efficient
approach for an integrated quality management program. FEMA officials
did not believe the revised approach limited the program management
contractor's independence or presented a conflict of interest. FEMA's
quality management plan called for independent verification and
validation of activities of the Program Manager as well as the mapping
contractors. FEMA officials stated that, in situations where program
activities of the program management contractor are to audited, FEMA
officials would either perform the audit or hire an external auditor.
Nevertheless, as we recently reported, the independence of the
verification and validation contractor is a key component of a
reliable verification and validation function.[Footnote 40] According
to industry best practices, the verification and validation activity
should be independent of the project and report directly to senior
management to provide added assurance that reported results on the
project's status are unbiased. An effective verification and
validation review process should provide an objective assessment to
management. The verification and validation reports should identify to
senior management the issues or weaknesses that increase the risks
associated with the project or portfolio so that they can be promptly
addressed. FEMA management has correctly recognized the importance of
such a function; however, the performance of the verification and
validation function by an entity that is technically, managerially,
and financially independent of the organization in charge of what it
is assessing could better position FEMA to help ensure the
independence of the verification and validation function, both in
appearance and in fact.
Documentation of Compliance Problems Does Not Facilitate Analysis:
Under FEMA's Independent Verification and Validation audit process,
the IV&V auditor is not required to present its findings in a format
readily conducive for performance monitoring and data analysis. For
example, according to one PTS contractor, FEMA advised its mapping
contractors that the IV&V audit findings are informational, rather
than actionable; therefore, the contractors are not required to
implement or track any changes. However, we found that at least one of
the PTS contractors does have a system for addressing corrective
action based on the IV&V audit findings--a corrective action process
that is documented in the contractor's Quality Management Plan that it
provided to FEMA. The corrective action process is used to address
deficiencies identified by the IV&V auditor and prevent future
occurrences during the mapping process, which are reported to FEMA
through a quarterly internal quality audit report.
Standards for Internal Control in the Federal Government states that
monitoring should assess the quality of performance over time and
ensure that the findings of audits and other reviews are promptly
resolved.[Footnote 41] In addition, we have previously reported that
when agencies lacked systematic analysis and reporting of data, it
adversely affected their ability to provide complete information on
the results of their operations.[Footnote 42] We reported that this
type of information could be useful to better understand the nature of
a problem, to help plan ways to address it, and to assess progress
made. In our analysis, we found that FEMA has several opportunities
for improving quality outcomes using its current practices. First,
FEMA could devise its own systematic data collection framework for the
audits. Second, FEMA could provide more guidance to the IV&V auditor
on how to present the audit findings. The IV&V auditor reported that
FEMA provided no guidance on how to present the results of the monthly
audits. FEMA could also require more comprehensive reporting as part
of its agreement with the mapping contractors, similar to the internal
efforts of the mapping contractor described above. The IV&V auditing
process could include all three mapping contractors and relevant
Cooperating Technical Partners, and FEMA could provide similar
guidelines for reporting metrics. The IV&V audits collectively produce
data that could be used to enhance FEMA's quality management if the
information is leveraged properly. For example, a database of audit
findings that is readily searchable could be used to identify trends,
quantity recurring problems, and potentially isolate mapping issues to
a specific region or PTS contractor. Therefore, in the absence of
systematic data reporting, FEMA's ability to establish a corrective
action plan to resolve issues, one of the key requirements of its
quality assurance management program, is greatly diminished. FEMA
officials stated that they have not required systematic data reporting
of IV&V audit results because they viewed the findings as isolated
cases to find individual map irregularities to assist regions in
improving map accuracy rather than potentially systemic issues.
However, FEMA officials agreed with our assessment that a methodical
approach to IV&V data collection could allow the agency to better
track map quality issues, better analyze the data, and more easily
adopt a corrective action plan. These actions could ensure that FEMA
adhere to its quality management plan and enhance map quality.
FEMA Has Taken Actions to Improve Outreach Efforts but Could Enhance
Its Efforts to Improve Awareness and Promote Map Acceptance:
FEMA Is Developing Toolkits and a Lessons Learned Library for State
and Local Mapping Stakeholders and Intends to Use Social Media Tools
to Reach Out to the Public:
FEMA has taken steps to increase the accessibility of outreach
toolkits and the awareness of outreach practices, through the Internet
and internet-based social media tools, to better equip state and local
officials with the resources needed to effectively reach out to the
public regarding flood mapping. FEMA previously developed and
distributed outreach toolkits for state and local officials at the
regional level by regional contractors. Under Risk MAP, FEMA's program
management contractor is developing standardized outreach toolkits for
state and local officials, which FEMA plans to provide nationally.
FEMA is also developing a Lessons Learned Library and a secure Web
site for flood mapping partners. As the outreach toolkits that include
standardized information and templates are developed, the site is
designed to share resources among FEMA regions and with state and
local officials. FEMA officials said that the site also includes
information from national and regional conferences that can be used by
FEMA Regions and state and local officials to conduct outreach to the
public. According to FEMA officials, FEMA Regions will use the secure
Web site to upload examples of their key practices and associated
materials.
In addition to better equipping state and local officials with the
resources needed to effectively reach out to the public, FEMA is also
conducting outreach directly to the public. Specifically, while FEMA's
regulatory and statutory flood mapping outreach requirements focus on
notifying the public about flood mapping through newspaper
publications and Federal Register notices, FEMA officials said they
were considering the use of social media sites as well.[Footnote 43]
FEMA has been engaging in internet-based social media tools and Web
sites nationwide as part of its mission to prepare the nation for
disasters. FEMA uses these tools--such as national-level news feeds
that provide subscribers with automated updated information and a
multimedia site that hosts videos, podcasts, photos and text-based
documents--for flood mapping outreach efforts as part of their
outreach strategy.
FEMA's Risk MAP goals with social media include providing timely and
accurate information related to disaster preparedness response and
recovery and providing the public with another avenue for insight into
the agency's operations. In addition, FEMA's use of social media
provides additional outreach and channels for input. According to
FEMA, citizens can engage more easily with the emergency management
community through social media sites, and increase their role in
disaster preparedness, response, and recovery. For example, FEMA has
been using Twitter since October 2008 as a means to offer information
about the agency's mission, efforts, and perspective. The agency also
launched a YouTube page in October 2008 to provide stories about how
its programs work in communities nationwide as they prepare for,
respond to, and recover from disasters. FEMA believes that these tools
could help the agency and its state and local mapping partners to more
effectively communicate with communities about flood mapping efforts.
FEMA Does Not Maintain Most Required Public Notification Documentation:
In our review of a random sample of files containing documentation of
public notification efforts, we found that FEMA does not maintain the
required documentation for public notification. Further, FEMA does not
have a process in place to ensure that its mapping partners
consistently document their actions to notify the public. FEMA is
required by law to document certain actions taken to notify the public
regarding the status of its flood mapping efforts. FEMA has
requirements in place for mapping partners to provide such required
documentation, but it does not have a process in place to ensure that
mapping partners are meeting these documentation requirements. As a
result, FEMA cannot be reasonably assured that it is complying with
public notification regulations.
FEMA is required to maintain a Flood Elevation Determination Docket
(FEDD) file for every local government that is affected by a flood
mapping project that results in a change in base flood elevation.
[Footnote 44] The FEDD file provides a record of all matters
pertaining to flood elevation determinations, including public
notification requirements established by the National Flood Insurance
Act of 1968. These FEDD files are required to contain documentation
demonstrating that a mapping contractor took the following six public
notification actions:
* notifying the community's CEO of the proposed flood elevation
determination,
* notifying the public of the proposed flood elevation determination
via an initial newspaper publication,
* notifying the public of the proposed flood elevation determination
via a 2nd newspaper publication,
* notifying the public of the proposed flood elevation determination
via a notice in the Federal Register,
* notifying the public of the final flood elevation determination via
a notice in the Federal Register, and:
* notifying the community's CEO of the final flood elevation
determination.
Based on our file review of a random sample of counties with flood
mapping projects, FEMA did not have a FEDD folder on file for
approximately 67 percent of the counties that had completed mapping
projects since 2005.[Footnote 45] We estimate that FEMA complied with
some, but not all documentation requirements for 16 percent of the
counties, and complied with all 6 documentation requirements for the
remaining 17 percent, as illustrated in figure 6 below. Because FEMA
does not sufficiently maintain documentation of its public
notification activities, the FEDD files do not provide a means for the
agency to provide reasonable assurance that it is complying with
public notification regulations. As a result, FEMA cannot use the FEDD
files to determine the extent to which a community was notified about
new mapping projects in accordance with the six public notification
actions.
Figure 6: Estimated Compliance Rates with FEMA Documentation
Regulations: Counties Having Flood Mapping Projects Since 2005 That
Resulted in a Change in Base Flood Elevation:
[Refer to PDF for image: pie-chart]
Compliance cannot be determined; FEDD file not found: 67%; Compliance
for all 6 of the required actions: 17%; Compliance for less than 6 of
the required actions: 16%.
Source: GAO analysis of FEMA data.
[End of figure]
FEMA officials said that they rely on mapping partners to document
completion of public notification requirements in FEDD files and FEMA
provides mapping partners with background on public notification
documentation requirements. FEMA also directs mapping partners to
document compliance with notification requirements in FEMA's Document
Control Procedures Manual. In reviewing FEMA's manual, we determined
that if mapping contractors followed the guidance in the manual, they
should be able to comply with public notification documentation
requirements. FEMA's manual provides details on the procedures to be
followed and the documents to be used for each NFIP map action
including FEMA-initiated, FEMA-contracted, and community-initiated map
studies and revisions.
FEMA relies on mapping partners to comply with these requirements, but
the agency does not have a process in place to ensure that these
mapping partners consistently document their actions to notify the
public. FEMA regulations require that public notification
documentation reside in FEDD files, which we observed as part of our
file review, as shown in figure 7 below.
Figure 7: GAO Analyst Examining Files at FEMA's Engineering Library:
[Refer to PDF for image: photograph]
Source: GAO.
[End of figure]
FEMA's contractor oversees its Engineering Library, where the hard
copy FEDD files are maintained. FEMA officials said that the agency is
aware that its mapping partners are not complying with public
notification documentation requirements and is drafting a procedural
memorandum that reiterates the processes that mapping partners are to
comply with to ensure that all documentation from completed studies
are sent to FEMA in a timely manner.
Standards for Internal Control in the Federal Government states that
controls should generally be designed to assure that ongoing
monitoring occurs in the course of normal operations. This may include
regular management and supervisory activities, comparisons,
reconciliations, and other actions to ensure compliance with
applicable laws and regulations. FEMA established its Mapping
Information Platform (MIP) to manage the mapping production process,
and the system includes data fields for each of the public
notification requirements, but the agency does not use the information
in the MIP to document compliance. Mapping partners have used the MIP
to document four of the six public notification requirements (related
to publications in the local newspaper for preliminary maps and the
Federal Register for preliminary and final maps). However FEMA
management does not have access to the two data fields in the MIP
related to requirements to notify the community's CEO of the proposed
flood elevation determination and of the final flood elevation
determination. FEMA officials said that these two fields could be made
accessible so that all six public notification requirements could be
documented by mapping partners in the MIP. FEMA officials said that
they do not use the MIP to document compliance with public
notification requirements because the FEDD folder is the official
record maintained for that purpose. A mechanism to monitor compliance
with public notification documentation regulations and statutes could
help FEMA obtain reasonable assurance that its contractors are
complying with documentation requirements, which can help FEMA ensure
that the public is being notified as required.
FEMA Could Better Assess the Effectiveness of Its Outreach Efforts:
FEMA is collecting some data on the quantity and nature of appeals to
the mapping studies, but the agency is not capturing data on all
appeals and protests in a manner that could be used to inform its
decisions about where to focus outreach efforts. Before flood maps
that result in a change in base flood elevation become effective,
regulations require that FEMA hold a 90-day appeals period. Appeals
and protests can be submitted by state and local officials or by
individual members of the public. Appeals challenge the proposed base
flood elevation based on technical or scientific inaccuracy, while all
other challenges to the flood maps are treated as protests. State and
local officials are responsible for collecting and reviewing all
individual appeals and protests and forwarding them to FEMA. An
official may also submit an appeal on behalf of the local government
itself. Figure 8 below provides an overview of the flood mapping
process and where the appeals period occurs in the process.
Figure 8: Overview of Outreach Steps in the Flood Mapping Process:
[Refer to PDF for image: illustration]
(A) Local Needs Identified: 1-6 months; Multi-Year flood hazard
identification; Scoping.
(B) Data Development Period: 12-24 months; Engineering & Mapping data:
Topographic, Hydrology, Hydraulics; Preliminary maps; Community
review: 30-day period.
1-2 weeks prior to 1st newspaper publication, publish BFEs on web. 1st
newspaper publication 7-10 days prior to start of appeal period. 2nd
newspaper publication; marks beginning of 90-day appeal period.
(C) Regulatory Adoption Period: 6-9 months; Appeal;
Map adoption.
(D) Map maintenance.
Sources: GAO analysis of FEMA data and Art Explosion clipart.
[End of figure]
FEMA divides appeals into two groups--eligible and ineligible. FEMA
defines eligible appeals as appeals from communities or individuals
which are based on knowledge or information indicating that the
elevations proposed by FEMA are scientifically or technically
inaccurate and that contain supporting documentation. To qualify as
eligible appeals, requests must also be submitted to FEMA within the
90-day appeal period. FEMA defines ineligible appeals as appeals that
do not meet these requirements--for example, if an appeal is based on
something other than the scientific or technical accuracy of the
elevations, or does not include supporting documentation.
During our analysis of the MIP, we found that FEMA does not broadly
capture information on the appeals and protest that can be used to
analyze trends nationally. For example, FEMA does not use the MIP to
track ineligible appeals or protests from local communities or
individuals, even though these appeals and protests may reflect state
and local officials' or the public's disagreement with a flood map.
Rather, when FEMA receives ineligible appeals or protests, it combines
the data in the MIP with comments that are received from state and
local officials prior to the end of the appeal period. FEMA then
labels all of the ineligible appeals, protests, and comments as
protests, even though ineligible appeals data could serve as an
indicator of the public's acceptance of, or resistance to, flood maps.
FEMA officials stated that they do not comprehensively collect and
analyze data on appeals and protests, as FEMA uses information in the
MIP for project-by-project supervision of flood map studies, rather
than as a strategic management tool to analyze trends. Also, FEMA has
not yet considered the costs and benefits of such analyses. We have
previously reported that in order to monitor progress, performance
data should be gathered to determine how well performance goals are
being achieved.[Footnote 47] While we recognize there is a cost
associated with collecting and analyzing all data on appeals and
protests, should FEMA determine that the benefits outweigh the costs,
taking such action could help FEMA evaluate the extent to which public
acceptance is being achieved and better target outreach activities to
more resistant communities.
In addition, FEMA has not established guidance for how to collect and
review appeals and protests, nor has it established guidance on how to
report appeals and protests data in the MIP. Instead, flood community
officials are directed to collect the appeals and protest data, review
them, and decide which ones to submit to FEMA. Once FEMA receives the
appeals and protests, it reviews them to determine whether they are
eligible. If any issues arise or if additional supporting data is
needed, FEMA will work with community officials, mapping contractors,
or other mapping partners to acquire it. FEMA resolves appeals using
the documentation originally submitted or it will consider additional
data or supporting information if supplied generally within 30 days.
However, in the absence of guidance on a standardized process, state
and local officials may collect and review appeals and protests in
different manners from one another, or from FEMA, and FEMA officials
stated that they do not know what process any one contractor used to
make its decisions about which appeals and protests to refer to FEMA.
For example, in the case of Hillsborough County, Florida, county
officials stated that they received over 1,000 appeals and protests.
The county hired a contractor to review the appeals and protests the
county received; the contractor consolidated them into approximately
400 appeals and protests, and responded to the remainder at the local
level, according to the contractor. After the contractor's review and
recommendation, the county submitted approximately 150 appeals and
protests to FEMA for review and disposition. FEMA officials then
aggregated these appeals and protests to input into the MIP, according
to FEMA officials. MIP records indicate that Hillsborough County,
Florida, has 60 appeals and protests from this study. Thus, more than
1,000 appeals and protests were condensed to a fraction of that total,
and FEMA has no way of knowing what criteria its contractor used when
making decisions about which appeals and protests it submitted to
FEMA. FEMA officials acknowledged that they have not established a
standardized process for contractors on how to enter appeals and
protest data.
In 2009, FEMA identified appeals and disputes arising from the study
and mapping process as a concern of mapping partners, and requested
the Association of State Floodplain Managers to review FEMA's mapping
processes to identify ways of improving the quality and effectiveness
of FEMA's communications with state and local officials prior to and
during the floodplain study and mapping process. This study is still
ongoing and is expected to be completed by the end of year 2010.
[Footnote 48] Standards for Internal Control in the Federal Government
provides that agencies to establish policies and procedures,
techniques and mechanisms to enforce management's directives.
Providing guidance to standardize the process mapping partners use to
make decisions about which appeals and protests to submit to FEMA
could help the agency better ensure it has complete information on
appeals and protests in each community.
FEMA Has Not Identified Performance Goals or Developed Measures to
Evaluate Its Efforts to Increase Public Acceptance of Flood Maps:
FEMA has not identified performance goals for public acceptance of
flood maps and has not developed measures to evaluate the extent to
which it would achieve these goals. FEMA's Risk MAP National Outreach
Strategy includes objectives for achieving 5 percent increases in the
publics' and local officials' awareness and understanding of flood
risk and future vulnerability to flooding by fiscal year 2011.
However, this strategy does not include a performance goal and
performance measures for the public's acceptance of flood maps. While
we recognize that developing measures to gauge public acceptance of
flood maps is not easy, it is possible to develop indicators of public
resistance to flood maps. For example, the volume of appeals and
protests of a particular mapping study could be an indicator of public
resistance to flood maps. Thus, FEMA could develop a performance goal
related to increasing public acceptance of flood maps and could use
ineligible appeals as an indicator of the public's resistance of flood
maps, which could serve as a performance measure for this goal. For
example, assuming that a certain percentage of individuals will be
opposed to a map if it requires them to purchase flood insurance, FEMA
could determine an expected rate of ineligible appeals and use this as
a baseline measure.
Our past work on the experience of leading organizations has
demonstrated that the principles of establishing measurable goals and
related measures, developing strategies for achieving results, and
identifying the resources that will be required to achieve the goals
are the basic underpinning for performance-based management--a means
to strengthen program performance.[Footnote 49] FEMA officials stated
that they have considered developing performance goals and measures
related to public acceptance of maps, but have not taken any action to
date. According to FEMA officials, the agency does not currently
collect information on outreach activities because it is not within
the scope of the Risk MAP Quality Assurance Management Plan. While
this plan identifies quality standards and metrics for outreach as
potential future scope, it does not identify in what years such
outreach metrics are to be addressed. Developing performance goals and
measures for public acceptance of flood maps could help FEMA better
determine whether its outreach efforts are achieving their intended
results.
FEMA Has Not Determined What Resources Are Needed for Outreach and Has
Not Established Risk-Based Mapping Priorities for Outreach Activities:
FEMA has not determined the financial or human resources that are
necessary to conduct flood mapping outreach efforts. FEMA officials,
and the state and local officials we spoke with in all four mapping
project we reviewed said that they devote most of their resources to
map production. As a result, outreach activities that could lead to
increased map acceptance may be under-resourced because map accuracy
is a higher priority for FEMA and its mapping partners. For example,
FEMA does not have a line-item in its budget for flood mapping
outreach, and agency officials said that outreach staffing costs are
paid out of general NFIP funds, and are not individually tracked. In
addition, FEMA is unable to analyze outreach spending within the CTP
program as a whole. However, while FEMA is able to track total state
and local contributions under their CTP contracts,[Footnote 50] FEMA
is unable to specifically track the amount of funding going toward
outreach versus other mapping activities, according to FEMA officials.
FEMA's Risk MAP strategy states as one of its goals to improve the
utilization of resources, but the agency cannot determine this if it
does not track the resources it is devoting to its various activities.
Furthermore, a key purpose of the Government Performance and Results
Act[Footnote 51] is to create closer and clearer links between the
process of allocating scarce resources and the expected results to be
achieved with those resources.[Footnote 52] FEMA officials stated that
annual budgeting for its flood mapping activities is allocated across
FEMA regions based on the regions' level of mapping activities and by
FEMA's risk based strategy, and it is up to each region to identify
the outreach personnel and resources needed within their regional
mapping budgets. However, FEMA officials could not provide us with
budget or expenditure information on outreach activities at FEMA
regions because FEMA has not established a reporting structure with
which the regions can provide that information to it.
In addition, while FEMA has developed its Risk MAP outreach strategy,
it has not developed a risk-based approach for conducting outreach
activities for flood mapping that could enable it to target resources
effectively. In 2004, as part of Map Modernization, FEMA established
risk-based mapping priorities by ranking all 3,146 counties from
highest to lowest for risk of flooding based on a number of factors,
including population, growth trends, housing units, flood insurance
policies and claims, repetitive loss properties, and flood disasters.
FEMA has not incorporated these risk-based priorities into its Risk
MAP outreach strategy. FEMA officials stated that risk class is
considered in an effort to anticipate possible outreach needs on a
case-by-case basis. According to FEMA officials, certain issues will
trigger a greater emphasis on outreach efforts. For example, as result
of an increased focus on protection provided by levees since 2005,
some communities--historically protected by levees--are now considered
to be Special Flood Hazard Areas and subject to mandatory purchase of
flood insurance.[Footnote 53] While FEMA's approach considers these
issues on a case-by-case basis, its response to events is reactive to
these events and does not enable FEMA to systematically plan and
budget its resources more efficiently and effectively. We reported in
December 2005, that risk management is a widely endorsed strategy for
helping policymakers make decisions about allocating finite resources.
[Footnote 54] By providing a reporting structure for regions to
identify and justify their outreach resource needs, FEMA could better
plan for and report on specific outreach activities for flood mapping
on a regional or national level. Likewise, by using risk in its
decisions regarding the allocation of outreach resources--for example,
by considering the number of high risk counties or the number of
mapping projects under way in a particular region--FEMA could ensure
that its resources for flood mapping outreach efforts are allocated in
the most effective manner.
FEMA Does Not Leverage FloodSmart Marketing Resources to Enhance Its
Outreach Efforts:
FEMA does not leverage its existing resources by using NFIP FloodSmart
marketing resources to enhance its flood mapping outreach efforts.
FEMA has three divisions in its Mitigation Directorate that share
roles and responsibilities in conducting outreach: the Risk Analysis
Division, the Risk Insurance Division, and the Risk Reduction
Division. The Risk Insurance Division is responsible for a marketing
effort called FloodSmart. According to FEMA, FloodSmart is a national
integrated marketing campaign that utilizes mail, television,
internet, and print media as marketing tools to promote the purchase
of flood insurance policies.
One mechanism FloodSmart uses to help market flood insurance is
through direct mail to the public. According to FEMA officials, to
support insurance agents in talking to their clients about flood
insurance, FloodSmart provides insurance agents access to a Mail-On-
Demand program through a Web site. The Mail-On-Demand program includes
a direct mail template that informs property owners about proposed map
changes in their community and how those changes may affect their
flood insurance needs. The Mail-On-Demand program allows insurance
agents to access a list of potential flood insurance purchasers. In
addition, this Web site contains a schedule that shows the preliminary
date, appeals dates, Letter of Final Determination date, and effective
dates for communities undergoing a mapping study.
FEMA FloodSmart officials said they also had developed two "toolkits"
of media materials that FloodSmart employees may provide to state and
local officials, insurance agents, and other stakeholders. One of the
toolkits is designed to provide information on the mapping process,
and the second toolkit provides information on levee safety and
certification and the effect of levees on FEMA flood maps. FEMA
Floodsmart officials said these media kits include general templates
of informational materials that can be customized for specific areas
and used to communicate the importance of flood insurance surrounding
map and levee changes to communities where the flood risk designation
has changed as a result of an assessment or flood mapping efforts.
According to FEMA officials, they created the map change toolkit
materials in partnership with Hillsborough County, Florida, and the
levee toolkit was developed in conjunction with the Sacramento Flood
Control Agency. They said they share the toolkits at industry and
stakeholder conferences, mail them out in response to specific
requests, and post the materials on FloodSmart.gov. FEMA's FloodSmart
marketing efforts are initiated at the request of a FEMA region.
FloodSmart team members said that, in those instances, they typically
do not send out direct mailers regarding the importance of flood
insurance until right before maps become effective. FEMA officials
stated that the Risk MAP program's outreach strategy is promoting
greater coordination and regular meetings between FEMA's FloodSmart
team, flood mapping staff, and FEMA staff responsible for floodplain
management.
FloodSmart marketing efforts could be used by FEMA in the process to
help promote community awareness, education, and acceptance of flood
maps. We have previously reported that collaborative efforts are
enhanced when agencies identify and address needs by leveraging
resources to support a common outcome.[Footnote 55] In this case,
FEMA's Risk Analysis Division and its Risk Insurance Division could
enhance their collaboration by applying this practice. Given that
FloodSmart already has efforts under way to help to educate the public
on the potential flood risk in communities and to encourage them to
take action, these efforts could be targeted toward educating the
public about, and encouraging public acceptance of FEMA's flood
mapping efforts. While FEMA officials stated that the Risk MAP
outreach strategy is promoting greater coordination with FEMA's
FloodSmart team, FEMA could enhance its flood mapping outreach efforts
by leveraging FloodSmart's marketing resources and expertise to
increase public acceptance of flood maps.
Conclusions:
The results of the flood mapping process on individual property owners
subject to resulting flood insurance requirements can be significant.
To effectively implement FEMA's 5-year Risk MAP program goal of
improving the accuracy of flood maps, FEMA will need to continue to
improve its data standards and its management processes. Since federal
law requires FEMA to assess the need to revise and update the nation's
flood maps at least every 5 years, determining how best to use mapping
resources will be crucial. Establishing separate measures of
compliance for detailed and approximate studies could allow FEMA to
better use FBS compliance rates as a measure of map accuracy; however,
the data necessary to accomplish this are presently not maintained by
the agency. By retaining and analyzing metadata, FEMA could report
additional information on FBS compliance and, thereby, have a
potentially better measure of map accuracy. Further, FEMA's NVUE
standard provides a basis for flood mapping partners to assess the
quality of new, validated, or updated engineering data in revising
maps; however, establishing uniform guidance for the validation of
existing data could help FEMA ensure mapping partners are consistently
validating data. This step could help FEMA both track and report the
accuracy of maps at the national and regional levels and better assess
mapping data needs. In addition, FEMA's IV&V process helps ensure that
mapping efforts are performed in accordance with minimum data quality
standards, procedures, and requirements. However, implementing
probability sampling during the IV&V auditing process, to the extent
that the benefits outweigh the costs, would ensure that the results
are generalizable and could help FEMA management use the information
more strategically. Likewise, to maintain the independence, both in
appearance and fact, of FEMA's verification and validation function,
this auditing function should be performed by an entity that is
technically, managerially, and financially independent of the
organization in charge of what is being assessed. And finally, in the
absence of systematic data reporting, FEMA's ability to establish a
corrective action plan to resolve issues identified through the IV&V
process, one of the key requirements of its quality assurance
management program, is greatly diminished.
Regarding outreach, FEMA has taken positive actions regarding its
innovative use of new media to enhance its outreach efforts. However,
there are areas in which FEMA could enhance its outreach efforts. For
example, without a mechanism to monitor mapping contractors'
compliance with public notification documentation requirements, FEMA
is limited in its ability to provide reasonable assurance that the
agency is notifying the public as required. Opportunities also exist
for FEMA to better utilize data on community appeals and protests to
inform its decisions about where to focus outreach efforts, and
provide guidance to standardize the process by which mapping partners
analyze appeals and protests data to the extent that the benefits
outweigh the costs. Moreover, without specific performance goals and
measures to assess the effectiveness of outreach efforts related to
flood mapping, it may be difficult for FEMA to determine whether its
outreach efforts are achieving their intended results. Further, by
providing a reporting structure for regions to identify and justify
their outreach resource needs, FEMA could better plan for and report
on specific outreach activities for flood mapping on a regional or
national level. Likewise, by using risk in its decisions regarding the
allocation of outreach resources--for example, by considering the
number of high risk counties or the number of mapping projects under
way in a particular region--FEMA could ensure that its resources for
flood mapping outreach efforts are allocated in the most effective
manner. Finally, FEMA has the opportunity to leverage existing
resources by broadening the scope of the FloodSmart program that
supports the NFIP to help promote public acceptance of flood maps.
Recommendations for Executive Action:
We are making 11 overall recommendations.
To address challenges in ensuring the accuracy of flood maps, we
recommend that the Administrator of the Federal Emergency Management
Agency:
* establish separate measures and collect data needed to assess
compliance with the Floodplain Boundary Standard for detailed and
approximate flood studies, and:
* establish uniform guidance for the validation of existing
engineering data to help FEMA fully implement the NVUE standard and
provide a basis for mapping partners to validate flood hazard data.
To enhance the independent verification and validation (IV&V) audit
process, we recommend the Administrator of the Federal Emergency
Management Agency:
* implement probability sampling during the IV&V audit process to the
extent that the benefits outweigh the costs, to ensure that the
results are generalizable for decisionmaking; and:
* transfer IV&V duties back to an independent entity to help ensure
impartiality; and:
* adopt a systematic approach to IV&V data collection, so FEMA can
better track map quality issues, more easily analyze the data, and
adopt a corrective action plan.
To address challenges in improving community outreach, we recommend
that the Administrator of the Federal Emergency Management Agency:
* establish a mechanism to better ensure compliance with the
documentation requirements of public notification regulations;
* collect and analyze data on appeals and protests, including those on
ineligible appeals, to the extent that the benefits outweigh the costs;
* issue guidance to mapping stakeholders to standardize the process
for analyzing appeals and protests and submitting this data to FEMA;
* establish performance goals and measures for promoting public
acceptance of flood maps;
* develop a reporting structure for regions to use to identify
resources needed to conduct flood mapping outreach activities, and
implement a risk-based approach to allocate outreach resources; and:
* leverage, as appropriate, existing FloodSmart marketing resources
and expertise to help increase public acceptance of flood maps.
Agency Comments and Our Evaluation:
We provided a draft of this report to DHS for review and comment. DHS
provided written comments, which are reprinted in appendix IV. DHS
also provided us with technical comments, which we considered and
incorporated as appropriate. We also provided a draft of this report
to the U.S. Army Corps of Engineers, but it did not provide written
comments on the report. However, in an email on November 3, 2010, the
Corps of Engineers liaison indicated that the Corps had no comments on
the report.
In commenting on the draft report, DHS stated that it concurred with
10 of the 11 recommendations. For the recommendations for which DHS
concurred, the agency identified actions taken or plans to implement
them. Specifically, FEMA agreed with our recommendation to establish
tracking and reporting that will allow FEMA to report the level of
precision by flood source. FEMA plans to implement this tracking as
part of the Coordinated Needs Management System that will be fully
implemented this fiscal year. FEMA agreed with our recommendation and
will finalize and issue uniform guidance for the validation of
existing engineering data under its New, Validated, or Updated
Engineering (NVUE) standard in this fiscal year. FEMA also agreed to
assess the additional costs and expected benefits to expand the scope
of the IV&V, and to implement probability sampling and will work with
the contractor performing audits to redesign the reporting of map
quality issues. FEMA stated it will issue guidance to address our
recommendations to ensure compliance with the documentation
requirements and to standardize the process for submitting appeals and
protests data to FEMA in order to improve the collection and analysis
of this information. FEMA also stated it will explore potential new
measures and look for ways to quantify and track outreach activities
that are integrated into map production activities. In addition, FEMA
also concurred with our recommendation to leverage existing FloodSmart
marketing resources, stating that FEMA's flood mapping program is
working with its FloodSmart program as part of the Risk MAP program to
identify areas where outreach effectiveness can be increased and
consistent messages can be delivered. These actions should address our
recommendations and help FEMA improve its efforts to ensure flood map
accuracy and enhance the agency's outreach efforts in developing and
implementing new flood maps.
DHS did not concur with our fourth recommendation that the
Administrator of the Federal Emergency Management Agency should
transfer independent verification and validation duties (IV&V) back to
an independent entity to help ensure impartiality. The department's
response stated that FEMA's Program Manager contractor is technically,
managerially, and financially independent of the flood hazard
development process and that the contractor is helping FEMA to
integrate the program, monitor program performance, and implement a
quality management process. FEMA believes that the quality audit
function is more effective if it is integrated into the overall
quality management process rather than performed externally to the
quality management process. However, as we noted in the report,
according to industry best practices, the verification and validation
activity should be independent of the project and report directly to
senior management to provide added assurance that reported results on
the project's status are unbiased. As FEMA states, its flood mapping
Program Manager contractor is an integral part of FEMA's flood mapping
program management, and as such we continue to believe that the
program management contractor's programmatic responsibilities and
involvement prevent it from having a clearly independent role in
validating and verifying the results of flood map production
activities, because the contractor has a vested interest in overall
program performance. Therefore, we believe that FEMA should transfer
independent verification and validation duties back to an independent
entity to help ensure impartiality.
We are providing copies of this report to interested congressional
committees, the FEMA Administrator, the Secretary of Homeland Security
and other interested parties. This report will also be available at no
charge on the GAO Web site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions concerning this report, please
contact me at (202) 512-8757 or by e-mail at jenkinswo@gao.gov.
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. Key contributors
to this report are listed in appendix V.
Signed by:
William O. Jenkins, Jr.
Director:
Homeland Security & Justice Issues:
[End of section]
Appendix I: Objective, Scope, and Methodology:
This report addresses the following objectives:
* To what extent has FEMA taken actions to enhance the accuracy of
flood maps and what challenges, if any, does FEMA face?
* To what extent has FEMA taken actions to help promote community
acceptance of flood maps, and what challenges, if any, does FEMA face?
We focused our review on those standards and processes related to
flood hazard mapping for rivers and streams (commonly know as
"riverine" flooding[Footnote 56]), as these account for about 95
percent of FEMA's flood maps. As a result, we limited our scope to
exclude those standards and processes related to flood hazard mapping
for coastal areas and the levee certification. In addition, FEMA has
processes to modify and update flood map information during the time
that a community's maps are in effect, called a Letter of Map Change,
which is also outside the scope of our work.
To evaluate the extent that FEMA has taken actions to ensure data
quality standards are consistently met for flood maps updated since
2005 and to what extent has FEMA measured whether implementation of
the data quality standards results in accurate flood maps, we analyzed
information on FEMA's policies and plans for flood map modernization
and data from FEMA's Mapping Information Platform (MIP) and systems
for documenting compliance with data quality standards. Specifically,
we reviewed documents including FEMA's Risk Mapping, Assessment and
Planning (Risk MAP) strategy, the Risk Map Multi Year Plan, and Map
Modernization Guidelines and Specifications for Flood Hazard Mapping
Partners and its associate appendices. We assessed FEMA's standards
and guidance to criteria developed in recent reports by the National
Academies of Sciences and the National Research Council, specifically
the Academies' report "Mapping the Zone: Improving Flood Map Accuracy.
[Footnote 57] We discussed the reports' methodologies with the authors
and with relevant FEMA officials, and analyzed reviews and critiques
of the Academies' reports to determine that they were appropriate for
our purposes. We tested the controls on the quality assurance/quality
control (QA/QC) process by extracting and reviewing data on all
projects initiated and completed for the period of October 2005
(corresponding to FEMA's Mid-Course Adjustment to its Map
Modernization Initiative) through 2009. We also reviewed FEMA's
Floodplain Boundary Standard (FBS) and New, Validated, or Updated
Engineering (NVUE) verification systems that were designed to track
implementation of data accuracy requirements. We tested the controls
on the FBS and NVUE compliance process by extracting and reviewing
data on all projects initiated and completed from fiscal year 2006
(when the FBS was established) through 2009 and compared them against
criteria in Standards for Internal Control in the Federal Government.
[Footnote 58] To assess the reliability of these databases, we
compared data to FEMA's management reports, interviewed FEMA's three
mapping contractors and reviewed the original data generated by these
contractors. We determined that the FBS and NVUE compliance data were
sufficiently reliable for the purposes of this report. We also
compared FEMA's QA/QC process to effective practices we have
identified for quality assurance.[Footnote 59] Finally, we discussed
FEMA's mapping process and standards with agency officials, as well as
officials from other federal stakeholders including the U.S.
Geological Survey, the National Oceanic and Atmospheric
Administration, the U.S. Army Corps of Engineers; national
organizations including the Association of State Floodplain Managers,
and National Association of Flood & Stormwater Management Agencies. We
also discussed FEMA's mapping process and standards with agency
officials, as well as officials from other federal stakeholders in
geographic data collection and mapping including the U.S. Geological
Survey, the National Oceanic and Atmospheric Administration, the U.S.
Army Corps of Engineers and the National States Geographic Information
Council; subject-matter experts on flood hazards and floodplain
management from national organizations including the Association of
State Floodplain Managers, and National Association of Flood &
Stormwater Management Agencies who are stakeholders to FEMA's mapping
initiatives, as well as state and local officials involved in mapping
projects we selected in Arizona, Florida, California, and North
Carolina (a discussion of the selection process is included below).
To assess the extent to which FEMA has taken actions to help promote
community acceptance, and ensured that regulatory requirements for
documenting public notification efforts are consistently met for flood
maps updated since 2005 we analyzed information on FEMA's policies and
plans for community outreach and data from FEMA's Mapping Information
Platform and systems for documenting compliance with statutory and
regulatory requirements for coordination with state and local
officials involved in mapping projects. Specifically, we reviewed
FEMA's previous Outreach Strategy for Map Modernization and its new
Risk MAP National Outreach Strategy, and analyzed the goals and
performance measures of FEMA's outreach strategy for Map
Modernization, and its new Risk MAP national outreach strategy against
our prior work reviewing federal agencies' practices for development
of national strategies compared it to effective practices we have
identified for national strategies,[Footnote 60] as well as review
FEMA's budget and staff allocations related to outreach. To assess
FEMA's internal controls and program management of community outreach
efforts, we examined several FEMA databases, including the Mapping
Information Platform (MIP), discussed above, designed to document
state and local mapping stakeholder information. As noted above, we
tested the controls on the MIP by extracting and reviewing data on all
projects initiated and completed from 2005 through 2009 and assessed
the reliability of these databases by checking them against documents,
such as FEMA's management reports and Flood Elevation Determination
Dockets (FEDD) that are established for each mapping project. We also
interviewed FEMA, state, and local officials involved in flood map
outreach to obtain their perspectives. For our review of FEMA's
compliance with public notification documentation requirements, we
examined FEMA's Flood Elevation Determination Dockets (FEDD) that are
established for each mapping project, selecting a probability sample
of 88 counties from a population of 431 counties that had completed
studies since 2005, that resulted in a change in base flood elevation.
From this probability sample we reviewed mapping partners'
documentation of compliance with six documentation requirements below:
* notifying the community's CEO of the proposed flood elevation
determination,
* notifying the public of the proposed flood elevation determination
via an initial newspaper publication,
* notifying the public of the proposed flood elevation determination
via a 2nd newspaper publication,
* notifying the public of the proposed flood elevation determination
via a notice in the Federal Register,
* notifying the public of the final flood elevation determination via
a notice in the Federal Register, and:
* notifying the community's CEO of the final flood elevation
determination.
Because we followed a probability procedure based on random
selections, our sample is only one of a large number of samples that
we might have drawn. Since each sample could have provided different
estimates, we express our confidence in the precision of our
particular sample's results as a 95 percent confidence interval (e.g.,
plus or minus 9 percentage points). This is the interval that would
contain the actual population value for 95 percent of the samples we
could have drawn. Percentage estimates based on our sample of counties
have 95 percent confidence intervals no wider than +/-9 percentage
points.
To supplement our analyses of FEMA's flood mapping internal controls
and program management activities related to both data accuracy and
community outreach, we selected four flood map modernization projects
in Arizona, Florida, California, and North Carolina. We selected these
locations based on our 2004 review to highlight specific challenges
associated with the mapping process, such as inclusion of levees, and
the impact of varying degrees of community involvement and outreach in
the 5 years since our review. Because we selected a nonprobability
sample of flood mapping projects, the results of the information
collected from these localities cannot be generalized to all mapping
projects but provided insights on the challenges experienced by these
localities.
We conducted this performance audit from August 2009 through December
2010, in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis
for our findings and conclusions based on our audit objectives.
[End of section]
Appendix II: Key Practices for Effective Communications to the General
Public:
In our discussion with localities, we identified a number of potential
key practices that FEMA, state and local officials, and mapping
partners identified as successful. These practices included getting
the public involved early-on in the mapping process through task
forces, holding open houses for the public to attend, and sending
direct mailers to the public. For example, Charlotte-Mecklenburg
County, North Carolina, has been recognized by county officials
involved with flood mapping outreach and subject matter experts in
flood mapping outreach as a leader in effectively using some of these
key practices. While a variety of factors can influence map
acceptance, Charlotte-Mecklenburg County officials reported zero
appeals and protests as a result of their 2005 mapping effort, and
North Carolina state officials reported very few appeals and protests
as a result of their most recent studies, which suggests their
outreach efforts may have been more successful than many other
counties'.
For example, Charlotte-Mecklenburg County, North Carolina, officials
stated that utilizing a land use task force was vital to the public's
acceptance of flood maps. To address the need for accurate current and
future land use data, a land use task force is convened to represent
the interests of the watershed. Task force members include homeowners'
association leaders, realtors' association members, and other local
leaders. The task force presents findings regarding the flood mapping
to the community and engages local media to do a story. This process
allows the county to gain vital support from the public and the county
to say that the data used in the flood mapping is approved by the
public. Furthermore, Charlotte-Mecklenburg county officials and state
officials both said that early involvement from the public can make
map acceptance easier later in the process. These officials stated
that if the public is presented with the facts and the study's
methodology early on, while it may be disgruntled when the maps are
created, it will be more supportive.
Another outreach technique that was used in 3 of the 4 locations we
reviewed was the use of community "open houses" set up by local
governments during the appeal period of the preliminary maps. The
official community meetings that FEMA holds with state and local
officials can be very formal and technical, so counties host separate
open houses for the public to attend, according to officials we spoke
to as part of our reviews of Charlotte-Mecklenburg, Hillsborough, and
Maricopa counties. These open houses are designed to accommodate
members of the public's different schedules and lets them drop-in at
any time. A variety of kiosks with brochures and staff are available
throughout the open house. The kiosks include mapping contractors and
county engineers who can provide information on modeling and data used
to create the flood map and insurance agents who can provide
information on insurance rates and grandfathering. FEMA officials
stated that they attempt to attend these open houses, but sometimes
their travel budgets prevent them from attending.
In addition, Charlotte-Mecklenburg county officials said that direct
mailers are also key to community acceptance of flood maps. The county
used targeted mailings to property-owners within the watershed that
was being mapped. They used these direct mailings in order to make the
public aware of the mapping study/project and to seek input. Charlotte-
Mecklenburg officials stated that the result of seeking input is a
worthwhile effort because it helps gain public support.
[End of section]
Appendix III: Summary of Studies and Related Findings from 1997
through 2009:
Data Quality and Community Outreach Are Long-standing Issues:
Data quality and community outreach are long-standing/inherent issues
in FEMA's flood mapping program. There have been other reviews of
flood map accuracy in the past:
In 2004, we reviewed Flood Map Modernization[Footnote 61]. We reported:
* Ensuring the accuracy and public acceptance of flood maps are
fundamental challenges inherent in federal efforts to establish and
maintain a national program.
* In developing digital flood maps, FEMA planned to incorporate data
that are of a level of specificity and accuracy commensurate with
communities' relative flood risk--there is a direct relationship
between the types, quantity, and detail of the data and analysis used
to develop maps and the costs of obtaining and analyzing those data.
* FEMA has developed partnerships with states and local entities for
mapping activities. However, the overall effectiveness of FEMA's
future partnering efforts was uncertain, especially in partnering with
communities with less resources and little or no experience in flood
mapping.
In 2009, the National Academy of Sciences published Mapping the Zone:
Improving Flood Map Accuracy,[Footnote 62] which reported that:
"...the extent of potential floods must be predicted from statistical
analyses and models; all of which have uncertainties that affect the
accuracy of the resulting flood map. Other findings include:
* The most appropriate flood study method to be used for a particular
map depends on the accuracy of the topographic data and the overall
flood risk, including flood probability, defined vulnerabilities, and
consequences.
* Flood maps with base flood elevations yield greater net benefits--
however, only the more expensive of FEMA's flood study methods--
detailed studies and most limited detailed studies--yield a base flood
elevation."
FEMA's 2001 food map progress report summarizes recommendations of the
Technical Mapping Advisory Council (established by Congress in the
National Flood Insurance Reform Act (NFIRA) of 1994 to provide
recommendations to FEMA on how to improve the accuracy, quality,
distribution, and use of Flood Insurance Rate Maps. Table 2 below
summarizes the findings and recommendations FEMA's flood mapping
program identified by these studies.
Table 2: Historical Data Quality Issues and Recommendations in FEMA's
Flood-Mapping Efforts:
1997 Technical Mapping Advisory Council[A]: Base Maps. Improve base
maps and review and update existing standards, in consultation with
the Federal Geographic Data Committee. Ensure strict adherence to the
Federal Geographic Data Committee's standards;
1998 Technical Mapping Advisory Council: 1. Map Availability and
Accuracy. Implement programmatic changes to improve accuracy,
reliability, and availability of digital and graphic map data.
2. Minimum Base Map Standards. Revise and ensure adherence to minimum
base map standards, consistent with Federal Geographic Data Committee
standards;
GAO 2004[B]: Develop and implement data standards that will 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;
OIG 2005[C]: Develop guidelines to help ensure compliance with FEMA's
minimum standard for producing accurate and reliable flood insurance
rate maps;
National Academies of Sciences (National Research Council) 2007:
Within the limits of the available elevation data, the updated
floodplain maps are adequate for this purpose. The nation's land
surface elevation data need to be modernized and mapped more
accurately to properly support FEMA Map Modernization and the nation's
flood-mapping and management needs. This report recommends a new
national digital elevation data collection is required. The committee
proposes that this program be called Elevation for the Nation;
National Academies of Sciences (National Research Council) 2009[D]:
The extent of potential floods must be predicted from statistical
analyses and models; all of which have uncertainties that affect the
accuracy of the resulting flood map. Other findings include:
* The most appropriate flood study method to be used for a particular
map depends on the accuracy of the topographic data and the overall
flood risk, including flood probability, defined vulnerabilities, and
consequences;
* Flood maps with base flood elevations yield greater net benefits--
however, only the more expensive of FEMA's flood study methods--
detailed studies and most limited detailed studies--yield a base flood
elevation.
Source: GAO.
[A] The Technical Mapping Advisory Council was established by Congress
in the National Flood Insurance Reform Act (NFIRA) of 1994 to provide
recommendations to FEMA on how to improve the accuracy, quality,
distribution, and use of Flood Insurance Rate Maps (FIRMs).
[B] GAO, Flood Map Modernization: Program Strategy Shows Promise, but
Challenges Remain, GAO-04-417 (Washington, D.C.: Mar. 31, 2004).
[C] Department of Homeland Security Office of the Inspector General,
Challenges in FEMA's Flood Map Modernization Program, OIG-05-44
(Washington, D.C., September 2005).
[D] National Research Council (U.S.). 2007. Elevation Data for
Floodplain Mapping. Washington, D.C.: National Academies Press.
http://books.nap.edu/catalog.php?record_id=11829 August 2007.
[E] National Research Council (U.S.), and United States. 2009: Mapping
the Zone: Improving Flood Map Accuracy. Washington, D.C.: National
Academies Press. http://www.nap.edu/catalog.php?record_id=12573 May
2009.
[End of table]
Appendix IV: Comments from the Department of Homeland Security:
Department or Homeland Security:
Washington, DC 20525:
November 4, 2010:
William 0. Jenkins Jr.
Director, Homeland Security and Justice:
441 G Street, NW:
U.S. Government Accountability Office:
Washington, DC 20548:
Dear Mr. Jenkins:
Thank you for the opportunity to review and comment on the Government
Accountability Office (GAO) draft report GAO-11-17, entitled, "FEMA
Flood Maps Some Standards and Processes in Place to Promote Map
Accuracy and Outreach, But Opportunities Exist to Address
Implementation Challenges."
The Department of Homeland Security appreciates the opportunity to
highlight current efforts that will not only comply with the
recommendations, but will also improve our overall operational
effectiveness. The recommendations and corrective actions to address
the recommendations are described below.
Recommendation 1: Establish separate measures and collect data needed
to assess compliance with the Floodplain Boundary Standard for
detailed and approximate flood studies.
Response: Concur. FEMA agrees with this recommendation to establish
tracking and reporting that will allow FEMA to report the level of
precision by flood source. FEMA plans to implement this tracking as
part of the Coordinated Needs Management System (CNMS) that will be
fully implemented this fiscal year. The CNMS system will provide
significantly improved national tracking and reporting on the flood
hazard data inventory.
Flooding sources with new and updated flood hazards must comply with
the floodplain boundary standard and CNMS will track the study method
for each flooding source.
Recommendation 2: Establish uniform guidance for the validation of
existing engineering data to help FEMA fully implement the New.
Validated, or Updated Engineering (NVUE) standard and provide a basis
for mapping partners to validate flood hazard data.
Response: Concur. FEMA will finalize and issue guidance for validation
and implement a full validation assessment of the flood map inventory
this fiscal year.
Recommendation 3: Implement probability sampling during the
independent verification and validation (IV&V) audit process to the
extent that the benefits outweigh the costs, to ensure that the
results are generalizable for decision-making.
Response: Concur. FEMA's current quality management process is
designed to yield acceptable quality level based on current standards.
FEMA will assess the additional costs to expand the scope of the IV&V
compared to the expected benefits.
Recommendation 4: Transfer independent verification and validation
duties back to an independent entity to help ensure impartiality.
Response: Non-concur. The Program Manager (PM) contractor is
technically, managerially and financially independent of the flood
hazard development process. The PM contractor is helping FEMA to
integrate the program, monitor program performance, and implement a
quality management process. FEMA believes that the quality audit
function is more effective if it is integrated into the overall
quality management process rather than performed externally to the
quality management process.
Recommendation 5: Adopt a systematic approach to IV&V data collection,
so FEMA can better track map quality issues, more easily analyze the
data, and adopt a corrective action plan.
Response: Concur. FEMA will work with the contractor performing audits
to redesign the reporting of map quality issues.
Recommendation 6: Establish a mechanism to ensure compliance with the
documentation requirements of public notification regulations.
Response: Concur. FEMA will issue a procedure memorandum to reinforce
the existing contract requirements to compile and archive this data.
FEMA will also transition to fully digital storage of this data on the
Mapping Information Platform (MIP) and incorporate a review of the
required deliverables into the quality management process.
Recommendation 7: Collect and analyze data on appeals and protests,
including those on ineligible appeals, to the extent that the benefits
outweigh the costs.
Response: Concur. FEMA will issue guidance consistent with
recommendation 8 (below), and implement changes to the current
tracking systems to implement this recommendation.
Recommendation 8: Issue guidance to mapping stakeholders to
standardize the process for analyzing appeals and protests and
submitting this data to FEMA.
Response: Concur. FEMA will issue guidance to support the
implementation of recommendation 7 (above).
Recommendation 9: Establish performance goals and measures for
promoting public acceptance of flood maps.
Response: Concur. FEMA currently measures the community adoption rates
for maps, which partially addresses acceptance, but has struggled to
identify an effective measure for acceptance. FEMA will explore
potential new measures, including the GAO's suggestion that measuring
appeals and protests might effectively measure public acceptance.
Recommendation 10: Develop a reporting structure for regions to use to
identify resources needed to conduct flood mapping outreach
activities, and implement a risk-based approach to allocate outreach
resources.
Response: Concur. A key component of the FEMA Risk Mapping,
Assessment, and Planning (MAP) program is that it formalizes several
outreach activities and products as part of a new standard project
work flow. These new elements provide the structure to plan, track and
report specific contract costs associated with flood mapping outreach.
FEMA will make revisions to the MIP workflow to update and track new
Risk MAP products and project level outreach and community engagements
for earned value and other program management requirements.
Additionally, FEMA will explore ways to analyze and allocate staff
outreach resources based on risk. FEMA will also look for ways to
quantify and track outreach activities that are integrated into map
production activities that have historically been difficult to
separate from production costs.
FEMA will define a process for allocating resources to Risk MAP
outreach based project risk, as well. FEMA anticipates that the risk
factors for outreach may differ from the risk factors used to allocate
engineering resources.
Recommendation 11: Leverage, as appropriate, existing FloodSmart
marketing resources and expertise to help increase public acceptance
of flood maps.
Response: Concur. As part of Risk MAP, the flood mapping program is
actively engaged with FloodSmart to identify areas where their
experience and work to date could increase our outreach effectiveness
and deliver consistent messages across FEMA programs.
Thank you for the opportunity to comment on this Draft Report. We look
forward to working with you on future Homeland Security issues.
Sincerely,
Signed by:
Jerald E. Levine:
Director:
Departmental Audit Liaison Office:
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
William O. Jenkins Jr., (202) 512-8757 or jenkinswo@gao.gov.
Staff Acknowledgments:
In addition to the contact named above, Chris Keisling (Assistant
Director), John Vocino (Analyst-in-Charge), Anthony Mercaldo, Justine
Lazaro, Jamie Berryhill, C. Patrick Washington, Linda Miller, David
Alexander, John Smale Jr, Jerome Sandau, Mark Ramage, Christine Davis,
and Tracey King made key contributions to this report.
[End of section]
Footnotes:
[1] According to FEMA, 20 to 25 percent of flood claims are to
communities and properties outside of a ’Special Flood Hazard Area“
(SFHA), which are those areas that have an estimated 1 percent annual
chance of flooding.
[2] GAO‘s High-Risk Series identifies federal programs and operations
that, in some cases, are high risk due to their greater
vulnerabilities to fraud, waste, abuse, and mismanagement. GAO, High-
Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-07-310] (Washington, D.C.: January
2007).
3] Pub. L. No. 111-83, 123 Stat. 2142, 2163 (2009); Pub. L. No. 110-
329, 122 Stat. 3574, 3675 (2008).
[4] 42 U.S.C. § 4101(e).
[5] For the purpose of this report, we will use the terms flood maps
to describe FEMA‘s flood insurance map products such as Flood
Insurance Rate Maps (FIRM), Digital Flood Insurance Rate Maps (DFIRM),
accompanying Flood Insurance Study and other supporting technical data.
[6] Federal Emergency Management Agency, Risk Mapping, Assessment and
Planning (Risk MAP): National Digital Elevation Acquisition and
Utilization Plan for Floodplain Mapping (Aug. 9, 2010).
[7] GAO, Flood Map Modernization: Program Strategy Shows Promise, but
Challenges Remain, [hyperlink, http://www.gao.gov/products/GAO-04-417]
(Washington, D.C.: Mar. 31, 2004).
[8] The Technical Mapping Advisory Council was established by the
National Flood Insurance Reform Act of 1994 to provide recommendations
to FEMA on how to improve the accuracy, quality, distribution,
dissemination, and ease of use of Flood Insurance Rate Maps, among
other things. Pub. L. No. 103-325, §576, 108 Stat. 2255, 2280 (1994).
The Council was created in November 1995 and it continued through
November 2000. The Council submitted recommendations to the Director
of FEMA in each of its Annual Reports.
[9] Department of Homeland Security Office of the Inspector General,
Challenges in FEMA‘s Flood Map Modernization Program, OIG-05-44
(Washington, D.C.: September 2005).
[10] National Research Council (U.S.), and United States. 2009 Mapping
the Zone: Improving Flood Map Accuracy. Washington, D.C.: National
Academies Press. [hyperlink,
http://www.nap.edu/catalog.php?record_id=12573] May 2009; National
Research Council (U.S.). 2007. Elevation Data for Floodplain Mapping.
Washington, D.C.: National Academies Press. [hyperlink,
http://books.nap.edu/catalog.php?record_id=11829] August 2007.
[11] FEMA created the Mapping Information Platform in 2004, to enable
the management, production, and sharing of flood hazard data and maps
and related information in a digital environment. In March 2006, FEMA
developed a Mid-Course Adjustment to its Map Modernization Initiative.
[12] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(Washington, D.C.: November 1999).
[13] Riverine flooding is flooding related to or caused by a river,
stream, or tributary overflowing its banks due to excessive rainfall,
snowmelt, or ice.
[14] The maximum margin of error for estimates of percentages from our
sample of flood mapping projects is plus or minus 9 percentage points
at the 95 percent level of statistical confidence.
[15] FEMA‘s requirement to maintain a flood elevation determination
docket (FEDD) is found at 44 C.F.R. § 67.3.
[16] See GAO Combating Terrorism: Evaluation of Selected
Characteristics in National Strategies Related to Terrorism,
[hyperlink, http://www.gao.gov/products/GAO-04-408T] (Washington,
D.C., Feb. 3, 2004), and GAO Financial Literacy and Education
Commission: Further Progress Needed to Ensure an Effective National
Strategy, [hyperlink, http://www.gao.gov/products/GAO-07-100]
(Washington, D.C., Dec. 4, 2006).
[17] Pub. L. No. 90-448, tit. XIII, 82 Stat. 572 (1968).
[18] Also included are Puerto Rico and the Virgin Islands.
[19] FEMA‘s Risk Reduction Division performs floodplain management
activities to reduce risk to life and property through the use of land
use controls, building practices and other tools, in both pre- and
post-disaster environments. FEMA‘s Risk Insurance Division provides
flood insurance for property owners and encourages communities to
adopt and enforces floodplain management regulations that mitigate the
effects of flooding on new and improved structures.
[20] [hyperlink, http://www.gao.gov/products/GAO-04-417].
[21] According to FEMA officials, the term "field survey" within FEMA
usually means actual survey measurements made by a crew on the ground,
and the term "field reconnaissance" is usually used within FEMA to
distinguish site visits to get an overall understanding of the area to
be studied and collect information other than survey measurements. In
addition, topographic data is mostly produced by aerial surveys,
although certain key features are often measured by field survey
because the aerial survey technology may not produce accurate results
in some situations.
[22] A Flood Insurance Study (FIS) is a book that contains information
regarding flooding in a community and is developed in conjunction with
the flood insurance rate map. The FIS, also known as a flood elevation
study, frequently contains a narrative of the flood history of a
community and discusses the engineering methods used to develop the
maps. The study also contains flood profiles for studied flooding
sources and can be used to determine Base Flood Elevations for some
areas.
[23] FEMA is required to contact community stakeholders, such as the
state coordinating agency and other appropriate community officials,
to discuss the intent and nature of the proposed flood map study. 44
C.F.R. § 66.5.
[24] FEMA is required to publish the proposed flood elevations in a
prominent local newspaper at least twice during the 10-day period
following the notification of the community chief executive officer.
Property owners have 90 days from the second newspaper publication to
appeal the proposed flood elevations. 44 C.F.R. §§ 67.4, 67.5.
[25] Final flood elevations must be published in the Federal Register
and copies sent to the community chief executive officer, all
individual appellants, and the state-coordinating agency. 44 C.F.R. §
67.11.
[26] 44 C.F.R. §§ 66.3, 67.3.
[27] Federal law provides that FEMA must encourage local officials to
disseminate information concerning a flood mapping study widely within
the community, so that interested persons will have an opportunity to
bring all relevant facts and technical data concerning the local flood
hazard to the attention of the agency during the course of the study.
42 U.S.C. § 4107.
[28] According to FEMA officials, production of these 2008 projects
under Map Modernization continued through 2010, and some of these
projects were still in progress at the time of our review.
[29] The total number of stream miles includes approximately 4.2
million miles of channels (waterways and rivers) and 600,000 miles of
coastline shorelines (open ocean, lakes, and ponds) in the United
States, according to the National Research Council, Committee on
Floodplain Mapping Technologies.
[30] GAO, Best Practices: Commercial Quality Assurance Practices Offer
Improvements for DOD, [hyperlink,
http://www.gao.gov/products/NSIAD-96-162] (Washington, D.C.: Aug. 26,
1996).
[31] The National Elevation Dataset is the primary elevation data
product of the U.S. Geological Service that contains the best
available elevation data of the United States. According to the
Service, the data set is updated on a two month cycle to integrate any
newly available, improved elevation source data that are processed to
a common coordinate system and unit of vertical measure.
[32] The limited circumstances under which FEMA would historically
provide funding for topographic data are detailed in FEMA‘s Geospatial
Data Coordination Implementation Guide (v2.2), (March 2008) p. 68.
Generally, FEMA only provides funding when existing elevation data are
inadequate, i.e., do not meet the minimum accuracy required in FEMA
flood mapping standards.
[33] Flood insurance purchase is mandatory for all federally backed
mortgages for properties in special flood hazard areas.
[34] For approximate studies, FEMA may include a BFE, but it not
considered a regulatory standard.
[35] See GAO Tax Administration: IRS Needs to Further Refine Its Tax
Filing Season Performance Measures, [hyperlink,
http://www.gao.gov/products/GAO-03-143] (Washington, D.C.: Nov. 22,
2002). GAO reported on nine key attributes of successful performance
measures. Linkage is defined as measure that is aligned with division
and agencywide goals and mission and clearly communicated throughout
the organization. Clarity is defined as a measure that is clearly
stated and the name and definition are consistent with the methodology
used to calculate it.
[36] Metadata is a concept that applies mainly to electronically
archived data and is used to describe the definition, structure, and
administration of data files with all contents in context to ease the
use of the captured and archived data for further use.
[37] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[38] Federal Emergency Management Agency, Risk Mapping, Assessment and
Planning (Risk MAP): National Digital Elevation Acquisition and
Utilization Plan for Floodplain Mapping, (Washington, D.C.: Aug. 9,
2010).
[39] Apptis, IV&V Audit Report (April 2010).
[40] GAO, Financial Management Systems: DHS Faces Challenges to
Successfully Consolidating its Existing Disparate Systems, [hyperlink,
http://www.gao.gov/products/GAO-10-210T] (Washington, D.C.: Oct. 29,
2009).
[41] GAO, [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[42] GAO, Firearms Trafficking: U.S. Efforts to Combat Arms
Trafficking to Mexico Face Planning and Coordination Challenges,
[hyperlink, http://www.gao.gov/products/GAO-09-709] (Washington, D.C.:
June 18, 2009).
[43] USA.gov introduces Web 2.0 and social media as umbrella terms
that define the various activities that integrate technology, social
interaction, and content creation. USA.gov cites FEMA as an example of
an agency that is using online content and technology to achieve its
mission and goals.
[44] 44 C.F.R. § 67.3.
[45] The maximum margin of error for estimates of percentages from our
sample counties is plus or minus 9 percentage points at the 95 percent
level of statistical confidence.
[46] 44 C.F.R. § 67.5.
[47] GAO, 2010 Census: Cost and Design Issues Need to Be Addressed
Soon, [hyperlink, http://www.gao.gov/products/GAO-04-37] (Washington,
D.C.: Jan. 15, 2004).
[48] In addition to contracting with ASFPM to review appeals process,
FEMA officials said that, beginning in November 2010, they planned to
implement an additional process for appeals resolution. Specifically,
FEMA has created an independent Scientific Resolution Panel that can
be convened when deemed necessary by FEMA or by a joint agreement
between FEMA and an appellant. The Scientific Resolution Panel is to
review and resolve conflicting data related to proposed BFEs as
provided for in the National Flood Insurance Act, as amended.
[49] For example, see GAO, Managing for Results: Enhancing Agency Use
of Performance Information for Management Decision Making, [hyperlink,
http://www.gao.gov/products/GAO-05-927] (Washington, D.C.: Sept. 9,
2005); GAO, Program Evaluation: Studies Helped Agencies Measure or
Explain Program Performance, [hyperlink,
http://www.gao.gov/products/GAO/GGD-00-204] (Washington, D.C.: Sept.
29, 2000); GAO, Agency Performance Plans: Examples of Practices That
Can Improve Usefulness to Decisionmakers, [hyperlink,
http://www.gao.gov/products/GAO/GGD/AIMD-99-69] (Washington, D.C.:
Feb. 26, 1999); and GAO, Managing for Results: Strengthening
Regulatory Agencies‘ Performance Management Practices, [hyperlink,
http://www.gao.gov/products/GAO/GGD-00-10] (Washington, D.C.: Oct. 28,
1999).
[50] According to the CTP program guidance, if a CTP has agreed to
perform outreach activities, FEMA may match funds from CTPs for
outreach activities up to 10 percent.
[51] Pub. L. No. 103-62, 107 Stat. 285 (1993).
[52] GAO, Performance Budgeting: OMB's Performance Rating Tool
Presents Opportunities and Challenges For Evaluating Program
Performance, [hyperlink, http://www.gao.gov/products/GAO-04-550T]
(Washington, D.C.: Mar. 11, 2004).
[53] In 2011, we plan to respond to a congressional mandate to review
FEMA‘s management of national levee systems.
[54] GAO, Risk Management: Further Refinements Needed to Assess Risks
and Prioritize Protective Measures at Ports and Other Critical
Infrastructure, [hyperlink, http://www.gao.gov/products/GAO-06-91]
(Washington, D.C.: Dec. 15, 2006).
[55] GAO, Results-Oriented Government: Practices That Can Help Enhance
and Sustain Collaboration among Federal Agencies, [hyperlink,
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21,
2005).
[56] Riverine flooding is flooding related to or caused by a river,
stream, or tributary overflowing its banks due to excessive rainfall,
snowmelt or ice.
[57] National Research Council (U.S.), and United States. 2009.
Mapping the Zone: Improving Flood Map Accuracy. Washington, D.C.:
National Academies Press. [hyperlink,
http://www.nap.edu/catalog.php?record_id=12573] May 2009.
[58] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(Washington, D.C.: November 1999).
[59] GAO, Best Practices: Commercial Quality Assurance Practices Offer
Improvements for DOD, [hyperlink,
http://www.gao.gov/products/NSIAD-96-162] (Washington, D.C.: Aug. 26,
1996).
[60] See GAO, Combating Terrorism: Evaluation of Selected
Characteristics in National Strategies Related to Terrorism,
[hyperlink, http://www.gao.gov/products/GAO-04-408T] (Washington,
D.C.: Feb. 3, 2004), and GAO, Financial Literacy and Education
Commission: Further Progress Needed to Ensure an Effective National
Strategy, [hyperlink, http://www.gao.gov/products/GAO-07-100]
(Washington, D.C.: Dec. 4, 2006).
[61] [hyperlink, http://www.gao.gov/products/GAO-04-417].
[62] GAO, Flood Map Modernization: Program Strategy Shows Promise, but
Challenges Remain, [hyperlink, http://www.gao.gov/products/GAO-04-417]
(Washington, D.C., Mar. 31, 2004).
[63] National Research Council (U.S.), and United States. 2009.
Mapping the Zone: Improving Flood Map Accuracy. Washington, D.C.:
National Academies Press. [hyperlink,
http://www.nap.edu/catalog.php?record_id=12573] May 2009.
[64] Federal Emergency Management Agency, Modernizing FEMA‘s Flood
Hazard Mapping Program: A Progress Report (May 2001).
[End of section]
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