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Appendix F: Levee-Related Observations, Conclusions, and Recommendations from Previous Reports
Pages 177-194

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From page 177...
... A Levee Policy for the National Flood Insurance Program (NRC, 1982) Existing levees should be recognized for the purpose of reducing insurance rates where they provide protection against 25-year or larger floods and where they meet specified structural design criteria, including requisite freeboard.
From page 178...
... Local officials of any NFIP participating community protected by a levee, regardless of its size and reliability, should prepare and promulgate an action plan for warning and evacuation in the event of levee failure. FEMA should help make local governments and special districts aware of the possibility of liability for actions or nonactions that aggravate flood hazards.
From page 179...
... The levee flood risk zones should match the existing flood risk zones established for the regular Flood Insurance programs FEMA should continue its efforts to establish an actuarial rate basis for the Flood insurance program and, as far as practical, convert its present rate schedule to actuarial rates. The actuarial rates as is done by the private insurance industry would be updated annually to reflect experience, claims paid, and the cost of doing business.
From page 180...
... FEMA should seek legislative authority to require mandatory purchase of flood insurance by those living behind accredited levees to address the residual risks they face and to ensure they are aware of this risk. Structures behind levees are subject to residual risks and should be insured against that risk.
From page 181...
... and in the Flood Insurance Study report. To ensure that levee systems maintain the conditions that qualified them for NFIP accreditation, FEMA should require as a condition of retaining FEMA recognition of levee status that sponsors: • Conduct annual inspections of the levee system, • Submit to FEMA biennially the results of the annual inspections, levee system operation and maintenance records, and an assessment of the levee system during any flood events that occurred within the reporting period, • Submit to FEMA every 10 years a report, prepared by a registered Professional Engineer or Federal agency responsible for levee design, that recertifies the engineering and geotechnical conditions of the levee system, • Certify levees as systems that include not only levees and floodwalls, but also the pumps, interior drainage systems, closures, penetrations, and transitions that provide systems integrity, and ensure that operation and maintenance plans cover all elements of the system.
From page 182...
... Recognizing the national and international movement toward use of risk analysis in dealing with floods and their consequences, the significant strides that have been made in developing risk assignment techniques, and the current use of these techniques by USACE in levee design, FEMA should modify 44 CFR 65.10 to phase out, over the next 10 years, use of the freeboard-based approach and should substitute the risk analysis methodology for levee-height determination. During the transition period, FEMA should permit either approach to be used in levee design and recertification analysis Strong consideration should be given to not recognizing, for NFIP purposes, levees that provide protection to highly urbanized areas unless they provide protection against floods greater than 100 years (e.g., the 500-year flood)
From page 183...
... FEMA, USACE and USGS should support R&D efforts focused on improvement of rapid assessment of levee geotechnical integrity and should jointly recommend to the National Science Foundation that attention be given to this area of research. ASFPM: National Flood Policy Challenges – Levees: The Double-Edged Sword (ASFPM, 2007)
From page 184...
... The ASFPM urges Congress and the Administration to adopt a policy that the 500-year level of protection for levee design is the minimal standard for purposes of flood insurance and other federal investment." Current levees that provide less than 500-year protection but meet all the requirements for design, maintenance, and operation, and are recognized by federal programs as meeting the standards for 100-year protection, could be provided grandfathered status. Criteria should be developed to determine when and if protection provided by a specific levee would need to be upgraded and how that would be achieved.
From page 185...
... State capability in this area is critical and can be developed most effectively through federal legislation that provides incentives and disincentives for states to accept delegation for the development and implementation of effective state levee safety programs. FEMA should require that all communities with an NFIP-recognized levee have a multihazard mitigation plan that considers how other hazards affect the safety of their levee (e.g., earthquake, subsidence, river sedimentation, erosion, etc.)
From page 186...
... Manage the floodplain by focusing new development outside of the floodplain or in low-risk locations within protected areas of the floodplain, supporting the use of undeveloped and unprotected land for agriculture and other low-intensity land uses.8 Floodplain management should be accompanied by requirements for local governments to adopt and enforce needed land-use controls, financial and technical support to enable them to do so, and appropriate penalties if local governments fail to manage development to reduce flood risk. The state should continue to support the Federal Emergency Management Agency's levee policy and assist them in accelerating completion and adoption of updated flood maps.
From page 187...
... This is especially the case for interior polderization of protected areas which could reduce the spatial extent of flood risk. TFH should work closely with local officials on full implementation of effective floodplain management and enforce that provision of Section 402 of the Water Resources Development Act (WRDA)
From page 188...
... Keep safety at the forefront of public priorities by having all responsible agencies re-evaluate their policies and practices to ensure that protection of public safety, health, and welfare is the top priority for infrequent but potentially devastating impacts from hurricanes and flooding. Also, encourage Congress to establish and fund a mechanism for a nationwide levee safety program, similar to that which is in place for dams.
From page 189...
... Develop Tolerable Risk Guidelines in order to facilitate an understanding of the options to reduce identified risks, how uncertainty affects this understanding, and to better inform levee construction/enhancement decisions and weigh nonstructural alternatives to flood risk management in a risk-informed context. Change "Levee Certification" to "Compliance Determination" to better articulate the intent that "certification" under the National Flood Insurance Program (NFIP)
From page 190...
... Develop a Comprehensive National Public Involvement and Education/Awareness Campaign to Communicate Risk and Change Behavior in Leveed Areas as an essential element of levee safety by improving public understanding of the role of levees, associated risks, and individual responsibilities to empower people to make risk-informed choices. Provide Comprehensive Technical Materials and Direct Technical Assistance crucial to the successful implementation of consistent national standards to states, local communities and owner/operators.
From page 191...
... Align FEMA's Community Rating System (CRS) to Reward Development of State Levee Safety Programs by providing further incentives to communities to exceed minimum program requirements and benefit from lower risk-based flood insurance rates to individuals who live in leveed areas.
From page 192...
... The process for incorporating new scientific information into large flood protection projects, like the New Orleans hurricane protection system, can be affected by congressional reauthorization requirements. Changes or clarifications to congressional policies and reauthorizations as they relate to large construction projects may be necessary to effectively implement findings of periodic scientific reviews.
From page 193...
... 2006. Assessing the Adequacy of the National Flood Insurance Program's One Percent Flood Standard.


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