3. Introduction to the Community Rating System
Applying to Participate in the CRS
Participation in the CRS is voluntary. To formally join and participate in the Community Rating System, a community must follow a standardized process that includes a verification that the community is properly administering and enforcing its floodplain management regulations and meeting several other prerequisites. It can take up to 2 years from that time that your community submits its application to actually join the program and receive a flood insurance discount as a result. While this is a significant time delay, it is necessary in order to determine if the community is eligible for the program and to verify that a community warrants the credit it requests. At its core, the CRS is an incentive program and as a result, the standards that must be met in order for a community to be rewarded for their actions are high. For more information reference page 210-1 of the CRS Coordinator's Manual.
Maintaining the CRS Class
Once a community has joined the CRS program, several activities are required in order to maintain enrollment. These activities fall into two categories, annual recertification and comprehensive verification visits in which an ISO/CRS Specialist re-calculates a community's CRS class. Annual reporting requirements to ISO are fairly minimal. A community enrolled in the program needs to recertify that it is meeting the prerequisites for its class, and that it has continued to implement and enforce the programs and/or regulations that it is receiving credit for. The documentation required for recertification will vary from community to community based on the activities and elements they are receiving credit for. The materials necessary for recertification will be sent by the ISO/CRS Specialist each year to the community. A community's annual recertification cannot be used in order to gain new CRS credit, in order to increase their CRS score, the community must apply for a modification (explained below). In general, the documentation and effort associated with recertification requires significantly less effort than preparing the documentation for a verification visit. Every year, notices for recertification are sent out to CRS communities in August and must be returned at the end of September. As a result, communities should anticipating spending no more than a month to assemble the required documentation.
Advancing in the CRS Program
In general, communities advance to higher classes in the CRS by putting together the documentation required to earn an additional 500 credit points. Communities rarely take an action for the sole purpose of earning credit points in the CRS. Rather, they complete the documentation or make the modifications necessary to meet the credit criteria for activities that their floodplain management, parks and recreation, and communication programs are already doing, or by the enforcing regulations that have already been implemented by their local government. For example, in Bellevue, Washington the city's parks department made the critical decision to preserve the land adjacent to the city's creeks and streams as open space in order to ensure that future generations would have access to these beautiful areas. These areas have since remained open to the public as park land which, the city receives credit for under Activity 420, Open Space Preservation. This city made a purposeful decision that was driven by the needs of their community, not by the prospect of receiving CRS credit. And yet this decision is something that the city can now be rewarded for. These stories are typical of communities that are enrolled in the CRS. As are stories of communities that voluntarily take-action because they feel it is the "right thing to do" regardless of whether or not they will receive credit. This sentiment was echoed by numerous communities that were interviewed for this project.
Another approach that could be employed is to use the creditable standards outlined in various CRS elements in order to inform or guide future planning efforts, regulation formulation, and standard setting. For example, the CRS Coordinator's Manual outlines a specific process that must be followed in order to receive credit for a community-planning efforts under Activity 510 Floodplain Management Planning. The CRS Coordinator's Manual also provides example ordinance language and standards that could be implemented to obtain credit under Activity 450 Stormwater Management Regulations. One approach that could be employed is to incorporate these standards into the community's ordinances and best practices. Even if these actions are not formally documented for CRS credit, simply implementing these standards, processes, and practices could help a community make progress towards becoming resilient. An added benefit to this approach is that, over time, a community could begin to compile the documentation necessary to obtain credit. In doing this they could reap the added benefits that CRS credit affords, mainly a reduction in insurance premiums for homeowners.
While the most common way to advance in the CRS is through a regularly scheduled verification visit, a community may ask for a "modification" to their CRS class once a year. A CRS modification can be completed in two different ways. First, if a community is requesting a modification to their score for an activity that it previously applied for, it must submit documentation for both new elements and those that were previously credited. Their ISO/CRS Specialist or Technical Reviewer then reviews, verifies, and rescores the activity for which new credit was requested. This type of modification is not considered a substitute for a full verification visit, and all activities and elements for the CRS will be reviewed at the time of ISO's next scheduled verification visit. Second, if a community is requesting a modification that could result in a change of two or more classes in the CRS, this will trigger a full verification visit to occur. When this occurs a community must be prepared to submit up-to-date documentation for all new and existing activities and elements for which they are seeking CRS credits. In addition, because this counts as a full verification visit, the community's cycle will be changed to reflect this visit. For more information on requesting and completing a CRS modification please refer to page 210-12 of the CRS Coordinator's Manual.
Special Class Criteria
As is to be expected with any incentive program, as the value of the incentive increases, the responsibility placed on the community that is earning said reward also increases. As a result, some special criteria must be met and maintained to obtain higher CRS classes. Specifically, special criteria must be met and maintained thereafter (referred in CRS as "prerequisites") in order to advance to Classes 6, 4, and 1. The class 4 and class 1 criteria include those that protect and enhance the natural functions of floodplains. These criteria are described briefly in the following paragraphs and are explained in much greater detail in the CRS Coordinator's Manual. See page 210-2 for more information.
To achieve class 4, among other things, the community must "demonstrate that it has programs that minimize flood losses, minimize increases in future flooding, protect natural floodplain functions, and protect people from the dangers of flooding, appropriate steps to eliminate or minimize future flood losses" by receiving credit for activities 430 Higher Regulatory Standards, 450 Stormwater Management, and 510 Floodplain management planning, receive at least 100 credits for elements that protect the natural and beneficial functions of floodplain, and document some life safety measures. Please see the CRS Coordinator's Manual page 210-4 for more information on these criteria.
To achieve a Class 1 rating, the community must demonstrate that it has adopted a No Adverse Impact (NAI) approach to floodplain management by earning credit under designated activities. No Adverse Impact is a floodplain management paradigm created and adopted by the Association of State Floodplain Managers (ASFPM), additional information on NAI can be found on ASFPM's NAI page. To date, only one community, Roseville, CA, has earned a Class 1 rating. For more information on how to advance to a Class 1, reference page 210-6 in the CRS Coordinator's Manual.
Stackable Credits
Within the CRS program are opportunities to count parcels of land or actions taken not once, but twice under different elements. When evaluating your community for opportunities to take credit, it is essential to keep stackable credits in mind. If your community is looking to earn more CRS credit by implementing new floodplain management activities, these stackable credits may be a good starting point as they can provide extra credit that goes above and beyond what could be earned normally. Within the CRS Green Guide elements, there are several opportunities for stacking credits. What follows is a summary of each.
Protecting Acquisition and Relocation Parcels as Open Space
Under Activity 520, communities receive credit for acquiring buildings that are within the regulatory floodplain, demolishing or removing them, and protecting that once-developed land as open space. Because these lands are required to be protected as open space in order to receive credit in Activity 520, they qualify not only for credit under Activity 520 but also under specific elements of Activity 420 Open Space Preservation. For example, all lands that qualify for credit under Activity 520 automatically qualify for credit under element 422.a. Open Space Preservation. If these lands are protected with a conservation easement or another kind of permanent deed restriction, additional credit can be granted under element 422.b. Deed Restrictions, and finally, if these acquired lands are restored to their pre-development condition and can be proven to provide some natural and beneficial floodplain function, additional credit can be earned under element 422.c. Natural Functions Open Space.
Bonus Points for Preserving Open Spaces
Activity 420 of the CRS rewards communities for preserving their community's floodplains as open spaces. Unlike other Activities of the CRS, Activity 420 can be thought of as a collection of almost entirely stackable credits. At a minimum all lands that are eligible for credit under this activity must meet the requirements of its first element, 422.a. Open Space Preservation. The other elements of this activity can then be thought of as opportunities to earn bonus points, each rewarding a different type of open space preservation. For example, areas that qualify for credit under element 422.a. Open Space Preservation and also are protected with a deed restriction can earn the community additional points for element 422.b. Deed Restrictions. Similarly, if that area is also in its pre-development condition, the community could earn additional points through element 422.c. Natural Functions Open Space. Other elements under activity 420 that could also be stacked along with element 422.a. Open Space Preservation and other elements under this activity include element 422.d. Special Flood-Related Hazards Open Space, 422.e. Coastal Erosion Open Space and element 422.h. Natural Shoreline Protection.
Rewards for Smart Development
While the avoidance strategy of floodplain management is rewarded heavily by the CRS, the program does provide opportunities to earn credit without preventing all development, including several opportunities to stack credits. For example, areas that are zoned such that their lot sizes are five or more acres are eligible for credit under element 422.g. Low Density Zoning. If the community's zoning ordinance also requires a developer to implement a sustainable land use planning technique like cluster development, these areas could also be eligible for credit under activity 422.f. Open Space Incentives. If these areas are also protected by regulations that manage how development is allowed to occur, for example prohibiting the placement of fill in the floodplain, they could be eligible for additional points under element 432.a. Development Limitations. Finally, if a community prohibits shoreline armoring, additional credit could be earned for element 422.h. Natural Shoreline Protection.
Taking Credit for State Requirements
In many cases, states set higher regulatory standards that communities implement and enforce either because they are mandatory or because the state has published model ordinances or other guidance documents that support their implementation. Communities that fully implement and enforce these state-set higher regulatory standards can be rewarded with CRS credit for their efforts. For example, states like Illinois, Wisconsin, and Michigan have floodway standards that exceed the NFIP Minimum Standards. These standards are creditable under the CRS, because despite being required by the state they are implemented at the local level. As a rule, communities must have the state-regulated feature within their community in order to take credit for it. Take for example a state like Wisconsin that has a setback requirement for development adjacent to navigable waterways (WI NR115.03). In this case, only Wisconsin communities with navigable waterways, which are subject to these regulations, would be eligible for credit. Finally, and most importantly, the amount of credit provided to any given community for a state regulation is based on impact adjustments, documentation, and enforcement that is done at the community level. As a result, communities should never anticipate receiving full credit simply because their state has a standard that is creditable under the CRS and should treat state standards no differently when documenting creditable activities.
To determine for which state regulations your community may be able to take credit, contact your State NFIP Coordinator and your ISO/CRS Specialist. Often times, they will have helpful information or at least some familiarity with state-regulations for which a community could potentially receive CRS credit. In addition, be sure to keep state-mandated and optional state requirements in mind when assessing actions your community is already taking or could easily implement in order to earn CRS credit.