September 14, 2022

CRS Reclassification Process Slowed by FEMA

In my last update on our efforts to get back into the Community Rating System, I passed along to you exactly what FEMA officials had been telling the city staff and CRS consultant:  that we were well on track to achieve the full restoration of our prior classification of 7, effective October 1, 2022.  All along the way staff have consistently been assured they’ve done everything asked of them, by every deadline.  And so imagine their surprise upon being informed last month that FEMA would now be pushing our reclassification out to October 1, 2023.

That notice prompted a series of further conversations, including the City Council’s encouragement to staff to continue advocating as strongly as they reasonably could, and to explore all options in pursuing what we’d been promised.  But on an all-hands conference call last week FEMA confirmed their decision to slow things down, citing the need for “measurable time to verify compliance with CRS requirements” and to ensure the City’s corrective action plan is being fully implemented and maintained.

Granted, their making us wait another year is consistent with how the reentry process normally works.  Recall what FEMA’s regional flood insurance liaison told us last September, about their agreeing to expedite a partial restoration of our rating, to a Class 9, effective at the very next cycle on April 1 of this year.  He noted specifically, “this is the only time that I have ever approved a community to come back in after a retrograde within six months.  Normally we require a year timeframe [for] the community to gather what they need [and] make sure they’re organized before they come back into the CRS program.”

So while they were apparently able to sidestep all that in approving our one-class modification for April, it seems they’d gotten a bit ahead of themselves when they previously committed to two more classes by October.  FEMA is requiring a full cycle visit for our two-class modification, and staff have already scheduled that with them, to get it done and out of the way early.  However, they’ve determined that a secondary CAV (Community Assistance Visit, essentially an audit), is not necessary in this case, which is great news.  They recognize the City’s past failures that resulted in our retrograde were limited to the individual personnel involved, and not indicative of a wider, systemic problem.  They continue to express confidence in the staff who subsequently inherited the situation and have been so diligent in addressing it.

Lest there be any misunderstandings, the folks at FEMA have been wonderful to work with and we truly appreciate their assistance and accommodation, including their having reclassed us to a 9 in April, which they didn’t have to do.  My intent here isn’t so much a complaint, and certainly not a personal attack, as it is a communication to our public as to what’s going on.  Especially given collective expectations based on what the City was told initially.  To be sure we’re disappointed by this latest development, but we do understand and respect where FEMA is coming from in its decision.