5. Green CRS Element Overview
The CRS Green Guide addresses 25 of the 90+ CRS Elements included in the 2017 CRS Coordinator’s Manual. The following section provides detailed summaries of each of the 25 CRS Elements.
These summaries or “element profiles” include critical information that communities can use to determine if:
- their current practices are creditable under the CRS, or
- they can feasibly implement the element (assuming their current practices are not creditable).
Specifically, each profile includes a summary of the element, the degree of difficulty associated with documenting and implementing it, the maximum number of points a community could earn, an overview any relevant impact adjustment and how it might impact a community’s credit-earning potential, co-benefits associated with the element, as well as a few “tips for success.” Most CRS elements discussed in the Green Guide are also associated with a success story that features a community’s experience with the element.
Impact Adjustments - Why They Matter and How They Influence Credit Calculations
While the CRS Coordinator’s Manual lists a maximum number of points a community can earn for each element, in reality, it is rare for a community to earn full credit for most of them. This is because credit is adjusted by ratios called impact adjustments. The CRS program uses impact adjustment ratios to calculate the portion of credit you will receive for implementing an action. Impact adjustments adjust CRS credit earned by a community based on the impact of implementing an element. Frequently, impact adjustments are calculated by taking the ratio of the area of the regulatory floodplain affected by a specific element relative to the total area of the regulatory floodplain. For example, for element 422.a. Open Space Preservation, credit is granted to communities for preservation of open spaces in the regulatory floodplain. The total amount of credit a community can earn for this element depends on what proportion of the regulatory floodplain is preserved as open space. To earn full credit for this element a community would need to protect the entire regulatory floodplain using open space.
This should not discourage CRS communities from pursuing credit under the CRS program, since there are far more credits available through the CRS program than are required to earn the highest possible discount and become a Class 1 community. To put this into perspective, a community could earn through the CRS program more than 7,700 points by simply implementing elements of the CRS in the Special Flood Hazard Area, but only 4,500 are required in order to become a Class 1. As a result, it is not necessary to earn full credit for any specific CRS element in order to succeed in the program.
Degree of Difficulty Estimates - What Do They Mean and How Were They Determined?
Each Green Guide element profile includes two estimates of “degree of difficulty.” The first (Degree of Difficulty -Documentation), provides an estimate of the amount of effort required to assemble the required CRS documentation for a creditable action a community has already taken. The second, (Degree of Difficulty - Implementation), provides an estimate of the amount of effort required to implement a CRS element in a community that does not already meet the credit criteria. Both are measured on a scale of low to high. In addition, both degree of difficulty estimates were generated by considering the “average” CRS community.
Table 2. CRS Green Guide Elements - Degree of Difficulty
What does the average CRS community look like?
According to a 2012 FEMA assessment, most CRS communities are a class 8 or 9 (FEMA, 2012). Meaning residents of these communities receive a 5-10% discount on their flood insurance premiums. In addition, as of January 2017 a majority of CRS communities have 1,000 or fewer flood insurance policies in their community (FEMA, 2016). Specifically, 42% of CRS communities have 100-1,000 flood insurance policies within their jurisdiction, and another 18% have fewer than 100 flood insurance policies in their jurisdiction (FEMA, 2016).
Why does it matter?
Every CRS community is different. Some already have higher regulatory standards in place, others are currently compliant with the NFIP minimum standards. Some CRS communities are rural and have very few flood insurance policies, while others are urbanized with many people living in the regulatory floodplain. An element that may be very difficult for a small, resource-constrained community to implement, might be much less challenging for a larger, well-staffed community to implement. As a result, these degree of difficulty estimates (while useful for making off the cuff judgements) should be taken with a grain of salt when determining whether or not to pursue CRS credit for an element.
Introduction to Activity 320 Map Information Services
Maps are vital sources of information to city staff, residents, and businesses alike. By making maps of flood-prone areas available to all members of the public, communities can raise residents’ awareness of natural hazards and empower them to make informed decisions about how to manage flood risk. That said, sometimes a community’s Flood Insurance Rate Map (FIRM) may be the only floodplain map available to communicate flood risk within a community. FIRMs, while vital to floodplain managers, can be complicated to understand and fail to adequately communicate flood risk as a result. In addition, communities often times have a wealth of additional quantitative or anecdotal data about flooding that is not adequately captured by a FIRM.
The purpose of this activity is to reward communities that voluntarily create additional maps that complement FIRMs by displaying additional information to help residents, developers, and local officials make informed land and water resource management decisions. Several examples of complementary maps cited in the CRS Coordinator’s Manual include maps of “additional hazards, flooding outside mapped areas, development regulations that affect floodplain properties, flood insurance, natural floodplain functions, and property protection measures.” For more information on this activity, please reference page 320-1 of the CRS Coordinator’s Manual.
Introduction to Activity 330 Outreach Projects
The purpose of this activity is to reward communities that use best practices to educate the public about flooding. In general, the public tends to underestimate flood risk (Committee on Levees and the National Flood Insurance Program, 2013). Engaging with the public through outreach projects is a critical way through which a community can raise residents’ awareness of flood hazards. That said, research has demonstrated that raising awareness is not necessarily enough to motivate changes in the public’s behavior that could help to mitigate or reduce their flood risk (Committee on Levees and the National Flood Insurance Program, 2013). Risk communication efforts can be made more effective if several best practices are adhered to: target messages toward specific audiences, acknowledge local norms and values, and encourage the recipient to make an appropriate behavior change (Committee on Levees and the National Flood Insurance Program, 2013). For more information see pages 330-1 - 330-5 of the CRS Coordinator's Manual, and chapter 7 of the National Research Council’s Report Levees and the National Flood Insurance Program: Improving Policies and Practices.
Introduction to Activity 410 Floodplain Mapping
The purpose of this activity is to reward communities for voluntarily adopting and enforcing floodplain regulations and maps that are more stringent than the minimum standards of the NFIP. The ultimate benefit of implementing the elements associated with this activity is that they provide a more holistic picture of flooding within a community and expand the area to which floodplain regulations and standards are applied. The areas that are typically mapped under this element are flooding problem areas that the community is aware of but, for one reason or another, were not mapped on the FEMA FIRM. Often times criteria that are more stringent than the NFIP mapping criteria are used to develop these maps. For more information on this activity reference pages 410-1 - 410-15 in the CRS Coordinator’s Manual.
Introduction to Activity 420 Open Space Preservation
Flooding is a natural process. When floodplains are maintained in their natural condition, they perform several natural and beneficial functions (Task Force on the Natural and Beneficial Functions of Floodplains, 2002). Most relevant to the CRS program is that floodplains store and convey floodwaters. Protection of open space in the floodplain prevents damage to structures since it essentially ensures that future development occurs outside of the floodplain. As a result, when flooding does occur, adverse impacts are limited because floodplains are allowed to naturally function. Recent studies have shown that earning credit under this activity is linked to significant savings in terms of flood losses (Highfield and Brody, 2013; Highfield and Brody, 2012). According to two studies of 450 CRS communities which participated in the program between 1999-2009, on average, a one point increase in CRS credit under Activity 420 was associated with savings of between $1,052-$3,532 per community per year (Highfield and Brody, 2013; Highfield and Brody, 2012). For more information on this Activity see pages 420-1 - 420-3 of the CRS Coordinator’s Manual.
- 422.a. Open Space Preservation (OSP)
- 422.b. Deed Restrictions (DR)
- 422.c. Natural Functions Open Space (NFOS)
- 422.d. Special Flood-Related Hazards Open Space (SHOS)
- 422.e. Coastal Erosion Open Space (CEOS)
- 422.f. Open Space Incentives (OSI)
- 422.g. Low Density Zoning (LZ)
- 422.h. Natural Shoreline Protection (NSP)
Introduction to Activity 430 Higher Regulatory Standards
The purpose of this activity is to reward communities for the implementation of standards, regulations, and/or ordinances that require new development, redevelopment and/or substantial improvements to be constructed in ways that are more stringent than NFIP minimum standards, or prohibit new development all together. These so called “higher regulatory standards” protect the natural and beneficial functions of floodplains and ensure that developed areas are resilient to future flooding. For more information see pages 430-1 - 430-6 of the CRS Coordinator’s Manual.
- 432.a. Development Limitations (DL)
- 432.l. Special Flood-Related Hazard Regulations (SHR)
- 432.n. Coastal Erosion Hazard Regulations (CER)
Introduction to Activity 440 Flood Data Maintenance
Maps are vital tools that help inform decision making. But maps are only as good as the data used to prepare them. Outdated maps and data that no longer reflect the nature of flooding and other natural hazards like coastal erosion, can limit the utility of these resources and ultimately, hinder their ability to inform decision making. The purpose of this activity is to encourage communities that make data used to develop or inform floodplain management activities like planning, regulation development or insurance rating more “accessible, current, useful and/or accurate.” For more information, see pages 440-1 - 440-3 of the CRS Coordinator’s Manual.
Introduction to Activity 450 Stormwater Management
The purpose of this activity is to prevent future development from adversely impacting downstream flooding and water quality. To achieve this end, the CRS program rewards communities for managing/regulating stormwater in ways that limit its contribution to flooding and for ensuring that the stormwater that does reach a community’s waterways will not degrade its quality. For more information reference pages 450-1 - 450-3 of the CRS Coordinator’s Manual.
- 452.a. Stormwater Management Regulations (SMR)
- 452.b. Watershed Master Plan (WMP)
- 452.c. Erosion and Sediment Control Regulations (ESC)
- 452.d. Water Quality Regulations (WQ)
Introduction to Activity 510 Floodplain Management Planning
Floodplain management planning is essential to community development. Through the floodplain management planning process, goals for the future of the community are established, and strategies for attaining those goals are outlined. In addition, development in areas that are at risk of flooding now or in the future can be avoided, or currently at-risk areas can be rezoned such that more sustainable redevelopment can occur. The purpose of this activity is to reward communities that create and/or maintain a current floodplain management plan through a standardized planning process and take actions to implement this plan every year. For more information see pages 510-1 - 510-3 of the CRS Coordinator’s Manual.
Introduction to Activity 520 Acquisition and Relocation
The purpose of this activity is to reward communities that acquire, relocate, and remove existing structures in the flood hazard area. Removal of structures from the floodplain is a proven strategy for flood risk and damage reduction. Although the upfront capital costs associated with land acquisition can be very high, in the long term it is much less costly to purchase these properties than to allow them to be repeatedly damaged and repaired over time. Due to the significant amount of overlap regarding the required documentation and co-benefits of the elements of this activity, the elements will be described together. For more information see pages 520-1 - 520-4 of the CRS Coordinator’s Manual.
- Activity 520
522.a. Buildings Acquired or Relocated (bAR)
522.b. Buildings on the Repetitive Loss List (bRL)
522.c. Severe Repetitive Loss Properties (bSRL)
Introduction to Activity 540 Drainage System Maintenance
Over time naturally occurring and constructed channels, detention basins, lakes, streams, etc. become filled with debris. Whether it is sediment, vegetation or fallen tree branches, this material can lower the total amount of water these structures and waterways can store or convey. Lakes, streams, channels and basins are just a few examples of critical green and gray infrastructure, which together, make up the drainage systems of communities. When these systems of naturally occurring and manmade drainage infrastructure become clogged with debris, flooding can be exacerbated. As a result, the CRS rewards communities that implement programs for maintaining their drainage systems. For more information on this CRS activity, see pages 540-1 - 540-5 of the CRS Coordinator’s Manual.