1. ASFPM Annual Conference Capitalizing on Your Authority for True Mitigation Mark Eberlein FEMA Region 10 Regional Environmental Officer

2. ASFPM Annual Conference 2011 2 Mitigation Purpose and Intent Authority Mission Statement What are we about?

3. ASFPM Annual Conference 2011 3 How do we Mitigate?  Avoid  Minimize  Rectify  Compensate Effectiveness Difficulty

4. ASFPM Annual Conference 2011 4 Executive Order 11988 Floodplain Management Intent Section 2(a)(2) Section 2(c)

5. ASFPM Annual Conference 2011 5 Water Resources Council Guidelines for Floodplain Management  8 step process  Step 3 Avoidance  Step 6 Re- evaluation

6. ASFPM Annual Conference 2011 6 44 CFR Part 9 Floodplain Management and Protection of Wetlands  Part 9.2 Policy  Part 9.6 Decision Making Process  Part 9.9 Analysis and reevaluation of practicable alternatives  Part 9.16 Guidance for Applicants  Part 9.17 Instructions to applicants

7. ASFPM Annual Conference 2011 7 What is “practicable?” Part 9.4 Definitions Capable of being done within existing constraints - Depends upon the situation - Includes consideration of pertinent factors -Environment -Cost -technology

8. ASFPM Annual Conference 2011 8 Implementing within HMA HMA Planning HMA Projects

9. ASFPM Annual Conference 2011 9 Implementing within HMA PLanning Best of the best (Enhanced Plans)  Florida  Wisconsin  Iowa  California  Washington

10. ASFPM Annual Conference 2011 10 Implementing within HMA Planning Step 3 Considered? Step 3 given a Hard look? Step 3 action or just words

11. ASFPM Annual Conference 2011 11 Implementing within HMA Planning Is FEMA Planning Guidance meeting our obligations under Part 9? Are our planning efforts having the results we want? Can we do a better job?

12. ASFPM Annual Conference 2011 12 HMA Project implementation Results of HMA funding  Data for Acquisitions/ all HMA projects  Data for Elevations/ all HMA projects

13. ASFPM Annual Conference 2011 Elevations for selected states Report on Elevation Projects in Select States by FY StateProgram FYApproved NetProject AmountProperties Elevated California1994-2011$47,601,929.10$61,735,904.101,087 Florida1995 - 2010$22,634,161.02$69,628,017.07762 Iowa1993 - 2007$10,359,459.00$17,794,485.6025 Washington1996 - 2011$31,849,898.68$37,538,011.50456 Wisconsin1993 - 2010$2,849,162.82$3,112,988.9730 13

14. ASFPM Annual Conference 2011 14 HMA Project implementation Hard Look  Are applicants meeting our instructions?  Does our guidance reflect the hard look?  Is the intent being fully met?

15. ASFPM Annual Conference 2011 15 What are we do to? Authority Policy Guidance Actions

16. ASFPM Annual Conference 2011 16 What are we do to? Risk Planning  Planning documents should reflect the hard look for avoidance  Vigorous analysis for continued occupancy needs to be addressed  Require prioritizations for avoidance  Require justifications for not avoiding

17. ASFPM Annual Conference 2011 17 What are we do to? HMA Projects  Fund only Acquisition projects unless demonstrated otherwise on practicability  Rigorous review of project criteria [Part 206.434(c)(3)] demonstrated at application, not at EHP review.

18. ASFPM Annual Conference 2011 18 What are we do to? Avoid Minimize Rectify Compensate Effectiveness Difficulty Upfront Effort

19. Questions? Mark Eberlein FEMA Region 10 Regional Environmental Officer