Green Guide

4. Best Practices for Implementing Green CRS Elements

To develop the CRS Green Guide, 35 interviews were completed with successful CRS Communities, ISO representatives, and state NFIP coordinators. Our goal was to learn what practices can lead communities to succeed in the CRS. The results of these interviews were used to generate the following best practices for success in the CRS:

1. Take credit for what your community is already doing: many communities are taking actions that are worth a substantial amount of credit and are simply unaware of it.
2. Be ready: use existing plans to set a course for action and have funds on hand to take action when the opportunity is ripe.
3. Invest in a GIS and data: they are the building blocks of several CRS Elements.
4. Create an inventory of property and natural resources in the floodplain: this inventory can help to establish a baseline for many CRS calculations.
5. Document things as they happen; taking the time to organize incoming data required to complete CRS calculations as it becomes available will save time in the long run.
6. Build partnerships and relationships: success in the CRS is much easier to attain when your CRS Coordinator has the support of the community, elected officials, and other departments.
7. Have an outreach plan: the CRS has multiple benefits, knowing what stakeholders care about can help to target outreach efforts and get their support.
8. Increase your community's administrative capacity by hiring consultants or teaming up with other CRS communities.
9. Design strategies to ensure that CRS information is transferred from leaving to incoming staff.

What follows in an in-depth description of each of these best practices as well as several examples of how communities have implemented them.

1) Take credit for what your community is already doing: many communities are taking actions that are worth a substantial amount of credit and are simply unaware of it. Earning credit in the CRS is not always associated with taking a new action or implementing a new practice. Rather, successful CRS communities have implemented floodplain management strategies that meet the needs of their residents, and have learned in subsequent years that these actions were creditable.

As a result, communities that have recently joined CRS or are simply looking to increase their score should review their existing plans, ordinances, restoration projects, and maintenance plans, to determine if any of their existing practices are eligible for credit. Some common elements for which most communities should receive credit include 452.c. Erosion and Sediment Control Regulations and 452.d. Water Quality Regulations, which align with the requirements of the MS4 permit. In addition, some characteristics of communities increase the likelihood that they will be able to capitalize on credit opportunities.

In some cases states have regulations in place that are above the minimum standards of the NFIP. In this case, many communities can earn credit for implementing and complying with these state regulations. For example, coastal communities in South Carolina are required to implement beach front management plans and establish a setback line, seaward of which new development is prohibited. The land protected by this setback is creditable under several elements of Activity 420 Open Space Preservation. To learn more about earning credit for state standards, read Myrtle Beach's success story and the Green Guide's description on taking credit for state regulations.

2) Be ready: use existing plans to set a course for action and have funds on hand to take action when the opportunity is ripe. Successful CRS communities had tools and resources ready when the opportunity to implement beneficial changes arose. Resources include using existing plans like comprehensive and hazard mitigation plans that can be used to prioritize actions; seeking-out model ordinances that could help to reduce flood risk in your community; and setting aside funds for land acquisition.

Pearland, TX, and Vicksburg, MS echo support for this best practice. Pearland, TX found that having standard requirements creates expectation. Pearland advocates creating ordinances that outline how floodplains will be managed, such as Chapter 10.5 Flood Damage Prevention of Pearland’s Code of Ordinances. The ordinance provides a clear way to guide community members and it acts as a base for how to respond to future flood events. Pearland, TX found that having standard requirements helps to manage community-members expectations.

3) Invest in a GIS and data: they are the building blocks of several CRS Elements. A Geographic Information System, or GIS, is a tool that can be essential to success in the CRS program. A GIS is a computer-based tool that allows users to analyze geographic data. Questions like: how many buildings are there in the floodplain? And, what percentage of the land in the Special Flood Hazard Area is parks? Can be answered with the help of a GIS and a person with the training necessary to use this software.

GIS can be a valuable tool for CRS Coordinators because the many elements with the highest credit-earning potential require communities to complete some kind of spatial analysis. Individuals with GIS expertise can come at a high cost depending on their experience level. As a result, capacity-limited communities should consider hiring a part-time contractor or a consultant to assist with CRS-related GIS work in advance of their verification visit.

That said, a GIS is only as good as the community's data. Communities that are lacking data on things like parcels of land in their community, land cover, the location and extent of the community's wetlands, open spaces, waterbodies, and watersheds should invest time (and sometimes money) in data collection efforts.  This is because these data are oftentimes integral to the creation of accurate and creditable impact adjustment maps. Some data, like parcel boundaries, can be obtained by working with the county which frequently maintain these data. Data on natural areas, endangered species, or wetlands, can sometimes be obtained by working with land trusts and conservation organizations. Data produced or maintained by federal agencies can also be valuable to communities. For example, the US Fish and Wildlife Service maintains a National Wetlands Inventory and NOAA maintain a registry of more than 1,500 datasets that pertain to coastal communities and counties through the Digital Coast. Finally, if a community needs to collect a new dataset, working with neighboring communities or regional entities to collect these data at a larger scale can be one strategy to reduce costs.

4) Create an inventory of property and natural resources in the floodplain: this inventory can help to establish a baseline for many CRS calculations. How many buildings are there in the floodplain? How many acres of open space are there in the floodplain? Are these numbers increasing or decreasing over time? The answers to these questions are vital to many calculations in the CRS program and can be gathered by taking stock of your community on a regular basis. In doing this, community staff can get a sense of what is currently in the floodplain, how much of the floodplain is developed, how much is parkland or natural open space, and most critically, over time, these data can help communities to understand how the landscape of the floodplain is changing in any given year from a development perspective.

As a result, communities without a GIS should create and maintain the following items abou the floodplain:

1. How many properties are in the floodplain (and how many of those properties are repetitive loss or severe repetitive loss),
2. How much open space there is in the floodplain (and how much of it is parkland, natural areas, and deed restricted),
3. How many threatened, endangered, or protected endangered species there are in the floodplain (if any), and
4. If the community is impacted by any of the special flood hazards credited by the CRS, and if so, how much of the community is at risk.

5) Document things as they happen; taking the time to organize incoming data required to complete CRS calculations as it becomes available will save time in the long run. Implementing floodplain management practices in your community, regardless of how beneficial they are to residents, is not enough to earn credit in the CRS. In order for an action to be creditable, a community must provide their ISO/CRS Specialist with evidence that the Specialist can use to verify that the community should receive credit and to facilitate accurate scoring. Oftentimes, CRS Coordinators wear many different "hats" in their community, meaning that the CRS is rarely the only task or primary duty to which they allocate their time. As a result, many communities overlook necessary CRS documentation maintenance.

Organization was reported to be the key to success by many communities. Creating a system through which the documentation required for a verification visit is collected in an organized manner can start with just a file cabinet or a folder on a computer. Having a standard procedure and  a place that is dedicated to collecting the files, correspondence, meeting records, and certificates necessary to document the actions of your community's floodplain management program is the first step towards organization. While the specifics of this organization system will vary by community, the most important take-away is to create a system that meets the unique needs of your community.

For example, the city of Birmingham, AL has developed a system in which all CRS materials are digitized and filed electronically as well as in file cabinets. Furthermore, as old information becomes outdated it is removed the city’s CRS-dedicated file cabinets and archived elsewhere. In addition, all electronic files are backed-up regularly to ensure that the community always has a recent copy of its files available in the event of an emergency. Moreover, while the city has had 3 different CRS Coordinator’s since 1993, all the city’s previous coordinators still work there. This has created continuity between coordinators and helped to prevent the loss of critical institutional knowledge on the program. For more information read Birmingham’s success story.

Another strategy for CRS organization is to minimize the amount of CRS-only paperwork that the coordinator must keep track of.  Some communities have devised clever systems in which they alter existing permits or have found ways to place the burden of proof onto property-owners in order to document creditable activities.

Finally, preparation for a verification visit should be an ongoing process, but often times does not become a priority until the months or weeks leading up to the visit. This leads to stress and requires more time in the long-run to track down specific documents than it would have taken to file them appropriately in the first place. It is highly recommended to make CRS documentation a routine process. In order to help communities to prepare for verification visits, ISO/CRS Specialists host 3-4 webinars each year. The schedule for these webinars can be found online.  For more information on best practices for CRS documentation, reach out to your CRS Users Group or your ISO/CRS Specialist.

6) Build partnerships and relationships: success in the CRS is much easier to attain when your CRS Coordinator has the support of the community, elected officials, and other departments. As was previously mentioned, success in the CRS is dependent on a community's ability to document their actions. Rarely does the CRS Coordinator have access to, or know about, all of the data being collected by their community that may be instrumental to obtaining CRS credit. Developing strong relationships with key staff in other departments, like the building official, the parklands manager, and stormwater engineers is essential to success in the CRS because they can provide the CRS Coordinator with the data necessary to document a creditable action.

Developing partnerships with external groups like your local CRS Users Group, other CRS communities, your state floodplain management association, local land trusts or other conservation groups, and even the neighboring counties and flood control districts can help to improve your CRS score. This is because these collaborative-relationships can help to promote peer-to-peer learning about earning CRS credit and implementing new practices in their community.

In addition to developing partnerships with neighboring communities, it is also critical for CRS communities to work with their elected officials and constituents when implementing creditable elements of the CRS. This is because the CRS can have substantial impacts on the community's residents and businesses. Talking with residents who will be potentially impacted by changes in regulations, policies, or programs that are associated with the CRS can help to overcome resistance to change, build trust, and encourage support.

For example, in Elm Grove, Wisconsin, initial offers to buy-out homes from property owners were rejected by homeowners. Ultimately only 1 of the 52 properties eligible to be bought were purchased. Later when the city offered property owners another opportunity to have their homes purchased, they made a coordinated effort to educate residents on why the buyouts were essential to the wellbeing of the community.

Finally, it is critical for CRS communities to build and maintain a relationship with their ISO/CRS Specialist. They are a valuable resource that can answer questions about the requirements of CRS elements, how they are scored, and what kinds of documentation are accepted. Over time this can help communities avoid common pitfalls and help save time that would have otherwise been spent looking for clarifying information that may not exist or be needed.

7) Have an Outreach Plan: The CRS has multiple benefits. Understanding what stakeholders care about can help target outreach efforts and get their support. The CRS can provide a wide range of benefits including: flood loss reduction, preservation of parks or natural areas, and insurance premium reduction.

Depending on what audience the CRS coordinator is appealing to, the relative importance of these benefits can vary. To elected officials, the main benefit of the CRS might be that it is a talking point to share with their constituents. To a homeowner, the most important benefit may be that their flood insurance premiums have been reduced, and to a conservation organization, the main benefit of the CRS may be the program’s promotion of open space preservation.

When talking with these three distinct audiences it is essential to address the unique concerns of each group, create and share information transparently, focus on consensus building, and frame discussion around protecting or realizing the “interests” of all stakeholders involved as opposed to defending specific “positions” or outcomes (Susskind & Field, 1996; Susskind, Levy & Thomas-Larmer, 2000). In doing this, the community can frame negotiations through the lens of maximizing the mutual benefits and minimizing the potential adverse impacts of a proposed action, which can help to reduce conflict in environmental disputes (Susskind & Field, 1996; Susskind, Levy & Thomas-Larmer, 2000). Public participation of this nature is critical because, when properly orchestrated, it has several advantages like enhancing trust in decisions and the public's acceptance of outcomes (Luyet et al., 2012).

These outcomes are ideal for communities as the CRS program is often associated with changes in the status quo, which may lead to frustration and resistance from the general public as well as stakeholder groups. NOAA's Office for Coastal Management has published several publications online that address best practices for public engagement. Most relevant to the CRS are their publications addressing risk communication and stakeholder participation basics. Climate Central has produced a CRS Guide for its Surging Seas tool. The Surging Seas CRS Guide address how this tool can be used for outreach, stakeholder engagement, and more.

8) Increase your community’s administrative capacity by hiring consultants or teaming up with other CRS communities. Consultants can be valuable resources in small and large communities. This is because they are experienced professionals who can be hired for short periods of time to help with specific tasks. If used effectively, consultants can help to expand the administrative capacity of a community so additional permanent staff are not needed. For example, the cities of Houston, TX, Birmingham, AL, and Sanibel, FL all used consultants to assist with the additional workload associated with orchestrating buyout programs in their communities.

Barnstable County Cooperative Extension, with the help of funding from Woods Hole Sea Grant, hired a regional CRS coordinator to assist its 15 small communities to enroll and/or advance in the CRS program. This first-of-its-kind position has already led to four communities applying for the CRS program. If all four are accepted to the program, this will double the total number of communities in the county that are participating in the CRS. Learn more by reading Barnstable County's success story.

9) Design strategies to ensure that CRS information is transferred from leaving to incoming staff. Staff turnover among community CRS coordinators is an unfortunate but common occurrence. Often new or incoming CRS coordinators are given little information on how the program operates, the history of the program in their community, and the network of individuals who can help them to find the information required for reporting purposes. As a result, when existing CRS coordinators leave, they take the working and institutional knowledge with them, essentially leaving the new coordinator to start from scratch.

Successful communities in the CRS often rely on networks of individuals to collect all of the information required for CRS documentation. In order to prevent the previously mentioned loss of institutional knowledge when CRS staffing changes occur, some communities designed strategies to help maintain continuity in spite of these changes. This can be as simple as creating a list of which departments and staff have specific CRS information, as well as a timeline of listing when this information should be collected.