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National Flood Policy—ASFPM 2015 Recommendations V. Climate Change V.1. Evaluate regional/local vulnerability of U.S. population centers to climate change impacts and provide adaptation options, especially for increased intensity or frequency of major storm events V.1.a Develop unified national policy/response plan to deal with the impacts of climate change, especially sea level rise, including mitigation prior to an event and response after an event. Develop minimum standards for the expenditure of all federal dollars following a disaster to account for anticipated climate impacts. V.2. Support/participate in data collection & analysis on impacts of and adaptation to climate change Sounds like another non-reg product (see comments on A1-5) Where will the expertise for the evaluation come from? Where will the funding for the adaptation options come from? Could this be the resilience index? LL V.3. Require analysis of impacts & adaptations to climate in all mitigation planning. Honeycutt: This should apply to more than just mitigation planning. Why so narrow a focus? V.4. Issue Executive Order to compel federal agency consideration of climate change impacts, or alternatively, support existing Federal requirements, recommendations or mandates that has Federal agencies integrating climate change considerations into their policies and procedures. Also see L.3 EO already exists in large part—sustainability and resilience Eos reserve executive orders for national emergencies where swift, decisive action is needed to avoid catastrophe. Climate change is not new, only the hype and general recognition of climate change. Climate change considerations are already part of many agencies' considerations under the category of best available science and data. Change to implement through F-S-L coop V.5. Revise federal agencies BCA methods to include projected impacts of climate change over the life of the project. As info becomes available Is this covered in P? NFPPR Combined comm rec and comments This exists… 13514, 13653, President’s Climate Action Plan, impending Federal Flood Risk Management Standard policy. Is there something specifically missing from these that require direction via an EO (vs. other implementing vehicle)? If so, call that out here. Honeycutt: Which agencies? As noted in another comment (W8), USACE has already implemented SLR for coastal planning/projects. One issue with this is that it assumes we have data needed to know what climate will do to flood risks in inland watershed – we don’t, certainly not on a national basis that would allow consistent application in BCAs. It may be premature to recommend this until we have more/better data on which to base climate-influenced flood hazard data for use in BCAs. Page 1 of 2 draft 10 9-14 National Flood Policy—ASFPM 2015 Recommendations V.6. Develop grant guidance to encourage/incentivize projects to address climate change V.7. Require all Class 7 and better CRS communities to consider and plan for climate change in their floodplain management plans, maps and regulations using available data Better yet, require that ALL CRS communities “consider and plan for climate change in their floodplain management plans, maps and regulations”; States should and could lead the way! Why Class 7 and above. Why not make it a category to earn points. There are places where Climate Change isn’t going to be an issue, so why penalize them? Add it to the CRS catalogue. V.8 Require all Class 4 and better CRS communities to include the impacts of land use and climate changes through 2100 in their mapping, planning, and regulations. NFPPR Combined comm rec and comments Why? Explain ……… What is the motivation here? To make Class 4 and higher CRS communities harder to achieve? Or are you wanting more emphasis on proper land use and climate change impacts / adaptation? This is way too vague! Page 2 of 2 draft 10 9-14