The report, made public on September 29, 2017, most notably uncovered that as of December 2016, only 42-percent of the total flood map miles in FEMA’s inventory were currently up-to-date and recognized as valid. This means that more than half of all catalogues flood maps require a re-study or still need to be assessed for validation.

A new audit report by the Department of Homeland Security’s Office of Inspector General (OIG) found that the Federal Emergency Management Agency’s (FEMA) management and oversight of the National Flood Insurance Program (NFIP) mapping program is lacking in several critical areas.

The report, made public on September 29, 2017, most notably uncovered that as of December 2016, only 42-percent of the total flood map miles in FEMA’s inventory were currently up-to-date and recognized as valid. This means that more than half of all catalogues flood maps require a re-study or still need to be assessed for validation.

“This falls well short of FEMA’s internal performance goal of 64-percent updated and valid flood maps, revised downward from 80-percent when it became clear that FEMA would not reach its goal,”a press release from OIG stated. “Auditors concluded that without the recommended improvements, FEMA cannot provide the public with a reliable representation of its true flood vulnerability or ensure that NFIP rates reflect the real risk of flooding.” 

According to OIG, flood hazard identification and subsequent mapping is “an integral part of the NFIP and a foundation for flood plain management, flood insurance, and flood mitigation.”

Local Background 

Almost three years ago, the FEMA Region VII Office in Kansas City undertook a review of 2011-era Flood Insurance Rate Maps (FIRM) for the area utilizing a new method of hydrologic analysis approved by the U.S. Geological Survey in 2014.

During a preliminary review of the proposed revised FIRMs in June 2016, the overall outcome of the review appeared to be good news with the amount of high hazard flood area generally less than the current area due to the base flood elevation (BFE) along some of the main tributaries of the Lake of the Ozarks being lowered.

The areas in Camden County that were most affected by the revised maps included portions of the Big Niangua, Little Niangua and Linn Creek. Nine panels in Camden County were updated, while two each were updated in Morgan and Miller counties.

The 90-day period to appeal the Federal Emergency Management Agency’s (FEMA) revised flood plain maps for the Lake of the Ozarks area concluded in early June of 2017 without any appeals filed to Camden County Floodplain Administrator Kim Willey. 

FEMA will soon issue a Letter of Final Determination that was scheduled to be released approximately 90 days after the appeal period ended. A six-month time period for local agencies to adopt the new floodplain maps as an ordinance will follow the Letter of Final Determination issuance.

The revised panels of the area floodplain maps would then become effective as law.

Audit Findings

The audit report describes several reasons for the federal agency’s inefficient oversight, including ineffective financial management of projects, an outdated life cycle cost estimate for its program and weak oversight of project progress, especially those postponed due to outside circumstances.

“Of the 88 projects tested by OIG auditors, 65 were on hold for more than a year,” according to the press release. “FEMA also lacks oversight to ensure that its flood mapping partners — such as private engineering firm contractors, state and local governments, and regional agencies — comply with FEMA’s guidance ensuring the quality of flood maps.”

OIG identified 240 of 1,947 (12-percent) active flood map projects that were on hold during the audit period, but focused the review on 88 of the 240 that were riverine flood map projects. A total of 28 were found to be on hold for an average of 2.9 years, impacted by new levee accreditation guidance, while 21 were on hold for an average of 2.6 years due to the period of performance for the mapping contract having expired.

“These projects could remain on hold indefinitely as FEMA may or may not fund to continue the project in the subsequent years,” according to the audit. “13 (of 15-percent) were on hold for an average of 2.9 years because the project was in the post or revised preliminary mapping process.”

The audit outlined four specific recommendations, which FEMA has already begun to address, listed below and as written in the report:

— Implement a system of tracking regional cost allocation for flood map projects including studies and other investments, as well as the status of funds (expended and unexpended) and where they are in their life cycle.

— Coordinate with the FEMA Chief Acquisition Executive Office to finalize and approve the RISK MAP LCCE. (Risk Mapping, Assessment and Planning Program life cycle cost estimate)

— Develop an effective oversight strategy and implementation plan including necessary policies and procedures to enable mapping projects to move forward on a timely and consistent basis.

— Revise policies and procedures to require Regional Project Managers to: ensure QR checklists and self-certifications are completed and uploaded into MIP; verify project data passes all Data Verification Tool checks prior to issuance of a flood map; and ensure documentation of all Data Verification Tool bypasses is uploaded to MIP.

Responses

“FEMA concurs with all of the recommendations. In its comments, FEMA noted that is has made significant progress developing and implementing several flood-related policy and program changes since OIG began this audit,” according to the 26-page report.

OIG’s analysis indicated that FEMA’s correction actions are responsive to the recommendations, but all four will remain open and unresolved until physical evidence can be produced to and assessed by the auditors.

“The recent flooding in Texas after Hurricane Harvey serves as a devastating example of the importance of accurate and reliable flood maps,” Inspector General John Roth said. “We are optimistic that our recommended changes will improve FEMA’s management of the flood mapping program and introduce internal controls to ensure the quality of the maps produced by FEMA’s partners.”