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Testimony: 

Before the Subcommittee on Housing and Community Opportunity, Committee 
on Financial Services, House of Representatives: 

United States Government Accountability Office: 

GAO: 

For Release on Delivery Expected at 10:00 a.m. EDT: 

Tuesday, July 12, 2005: 

Flood Map Modernization: 

Federal Emergency Management Agency's Implementation of a National 
Strategy: 

Statement of William O. Jenkins, Jr., Director, Homeland Security and 
Justice Issues: 

GAO-05-894T: 

GAO Highlights: 

Highlights of GAO-05-894T, a report to Subcommittee on Housing and 
Community Opportunity, Committee on Financial Services, House of 
Representatives: 

Why GAO Did This Study: 

Floods inflict more damage and economic losses upon the United States 
than any other natural disaster. During the 10 years from fiscal year 
1992 through fiscal year 2001, flooding resulted in approximately $55 
billion in damages. The Federal Emergency Management Agency (FEMA) is 
responsible for managing the National Flood Insurance Program (NFIP). 
The program uses flood maps to identify the areas at greatest risk of 
flooding and make insurance available to property owners to protect 
themselves from flood losses. According to FEMA, many of the nation's 
flood maps are more than 10 years old and no longer reflect current 
flood hazard risks because of erosion and changes in drainage patterns. 
Moreover, because many flood maps were created or last updated, there 
have been improvements in the techniques for assessing and displaying 
flood risks. 

This testimony is based on GAO’s findings and recommendations in its 
March 2004 report related to (1) how map modernization intended to 
improve the accuracy and accessibility of the nation's flood maps, (2) 
what the expected benefits of more accurate and accessible flood maps 
are, and (3) to what extent FEMA's strategy for managing the map 
modernization program support the achievement of these benefits. 

What GAO Found: 

Through map modernization, FEMA intends to produce more accurate and 
accessible flood maps by using advanced technology to gather accurate 
data and make the flood maps available on the Internet. For example, 
displaying map data in digital Geographic Information Systems format 
permits consistent, accurate display, and ready electronic retrieval of 
a variety of map features, including elevation data and the location of 
key infrastructure, such as utilities. 

FEMA expects that by producing more accurate and accessible digital 
flood maps through map modernization, the nation will benefit in three 
ways. First, communities can use more accurate digital maps to reduce 
flood risk within floodplains by more effectively regulating 
development through zoning and building standards. Second, accurate 
digital maps available on the Internet will facilitate the 
identification of property owners who are statutorily required to 
obtain or who would be best served by obtaining flood insurance. Third, 
accurate and precise data will help national, state, and local 
officials to accurately locate infrastructure and transportation 
systems (e.g., power plants, sewage treatment plants, railroads, 
bridges, and ports) to help mitigate and manage risk for multiple 
hazards, both natural and man-made. 

At the time of GAO’s review, FEMA had not yet established clear 
standards for the types, quantity, and specificity of data collection 
and analysis associated with different levels of flood risk. We 
recommended that FEMA develop standards to better ensure that data 
collection and analysis is consistent for all communities with similar 
risk and that it is using its resources efficiently while producing 
maps that are accurate and useful for communities at different levels 
of flood risk. In November 2004, FEMA issued its Multi-Year Flood 
Hazard Identification Plan. The plan describes FEMA’s strategy for 
addressing GAO’s recommendation by using varying types of data 
collection and analysis techniques to develop flood hazard data in 
order to relate the level of study and level of risk for each county. 

GAO concluded that FEMA’s performance measures would not effectively 
measure the extent to which the agency’s map modernization program 
would result in its primary intended benefits. As a result, GAO 
recommended that FEMA develop and implement useful performance 
measures. In response to GAO’s recommendation, FEMA has set target 
percentages in its Multi-Year Flood Hazard Identification Plan for four 
key performance indicators in fiscal years 2006 through 2009. FEMA’s 
four indicators are (1) Population with Digital GIS Flood Data 
Available Online, (2) Population with Adopted Maps that Meet Quality 
Standards, (3) Percent of Effort Leveraged; that is, state and local 
resources provided for map modernization as a percentage of FEMA 
resources provided, and (4) Appropriated Funds Sent to Coordinating 
Technical Partners. 

www.gao.gov/cgi-bin/getrpt?GAO-05-894T. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact William O. Jenkins, Jr. 
at (202) 512-8757 or jenkinswo@gao.gov. 

[End of section]

Mr. Chairman and Members of the Subcommittee: 

I appreciate the opportunity to participate in today's hearing to 
discuss the Federal Emergency Management Agency's (FEMA) national flood 
map modernization program.[Footnote 1] My testimony is primarily based 
on our March 2004 report on FEMA's map modernization efforts.[Footnote 
2]

Floods inflict more damage and economic losses upon the United States 
than any other natural disaster. During the 10 years from fiscal year 
1992 through fiscal year 2001, flooding caused over 900 deaths and 
resulted in approximately $55 billion in damages.[Footnote 3] Since its 
inception 36 years ago, the National Flood Insurance Program (NFIP) has 
combined the development of flood maps to identify the areas at 
greatest risk of flooding with mitigation[Footnote 4] efforts to reduce 
or eliminate flood risks to people and property and the availability of 
insurance that property owners can purchase to protect themselves from 
flood losses. The flood insurance program has paid about $12 billion in 
insurance claims, primarily from policyholder premiums, that otherwise 
would have been paid, at least in part, from taxpayer-funded disaster 
relief. 

Accurate flood maps that identify the areas at greatest risk of 
flooding are the foundation of the NFIP. The maps are principally used 
by (1) the approximately 20,000 communities participating in the NFIP 
to adopt and enforce the program's minimum building standards for new 
construction within the maps' identified floodplains, (2) FEMA to 
develop accurate flood insurance policy rates based on flood risk, and 
(3) federally regulated mortgage lenders to identify those property 
owners who are statutorily required to purchase federal flood 
insurance. Under the National Flood Insurance Act of 1968, as 
amended,[Footnote 5] property owners whose properties are within the 
designated floodplain and have a mortgage from a federally regulated 
financial institution are required to purchase federal flood insurance. 

Flood maps can become outdated for a variety of reasons, such as 
erosion or community growth and development that can affect the 
drainage patterns of rainwater. Thus, flood maps must be periodically 
updated to assess and map changes in the boundaries of floodplains that 
result from community growth, development, erosion, and other factors 
that affect the boundaries of areas at risk for flooding. 

With congressional support and funding, last year FEMA embarked on a $1 
billion, 5-year effort to update the nation's flood maps. Today, I am 
here to discuss the findings and recommendations of our March 2004 
report. My remarks today will focus on (1) how map modernization is 
intended to improve the accuracy and accessibility of the nation's 
flood maps; (2) what the expected benefits of more accurate and 
accessible flood maps are; and (3) to what extent FEMA's strategy for 
managing the map modernization program supports the achievement of 
these benefits. 

To answer these questions, we analyzed available information from FEMA 
on the program's purpose, objectives, and status and met with agency 
officials in headquarters and in the regional offices to discuss the 
program's progress. We also conducted site visits to states and 
communities that have already begun to modernize their flood maps and 
interviewed industry organizations such as the Association of State 
Flood Plain Managers, the National Association of Flood and Stormwater 
Management Agencies, and the National Emergency Management Association. 
We conducted our work from April 2003 to March 2004 in accordance with 
generally accepted government auditing standards. 

Summary: 

In summary, we found: 

* Through map modernization, FEMA intends to produce more accurate and 
accessible flood maps by using advanced technology to gather accurate 
data and make the flood maps, and the digital information on which they 
are based, available on the Internet. For example, displaying map data 
in digital Geographic Information Systems (GIS) format permits 
consistent, accurate display, and ready electronic retrieval of a 
variety of map features, including elevation data and the location of 
key infrastructure, such as utilities. According to FEMA, nearly 70 
percent of the nation's approximately 92,222 flood maps were more than 
10 years old at the time of our review. Many of these maps no longer 
reflect current flood hazard risks because changes such as erosion and 
development can alter drainage patterns and, thus, the areas at highest 
risk of flooding. Moreover, since many flood maps were created or last 
updated, there have been improvements in the techniques for assessing 
and displaying flood risks. 

* FEMA expects that by producing more accurate and accessible digital 
flood maps through map modernization, the nation will benefit in three 
ways. First, communities can use more accurate digital maps to reduce 
flood risk within floodplains by more effectively regulating 
development through zoning and building standards. Second, accurate 
digital maps available on the Internet will facilitate the 
identification of property owners who are statutorily required to 
obtain or who would be best served by obtaining flood insurance. Third, 
accurate and precise data will help national, state, and local 
officials to accurately locate infrastructure and transportation 
systems (e.g., power plants, sewage treatment plants, railroads, 
bridges, and ports) to help mitigate and manage risk for multiple 
hazards, both natural and man-made. 

* FEMA's strategy for managing map modernization is designed to support 
the expected program benefits, but FEMA's approach to implementing the 
strategy raised several concerns that we concluded could hamper the 
agency's efforts. FEMA's implementation approach is based on four 
objectives: (1) establish and maintain a premier data system, (2) 
expand outreach and better inform the user community, (3) establish and 
maintain effective partnerships, and (4) achieve effective program 
management. 

* Establish and maintain a premier data system: Although FEMA's efforts 
to establish a new data system could result in more accurate flood maps 
and make it easier to access and use the revised flood maps, at the 
time of our review, FEMA had not yet established clear standards for 
the types, quantity, and specificity of data collection and analysis 
associated with different levels of flood risk. FEMA had ranked the 
nation's 3,146 counties from highest to lowest flood risk. According to 
FEMA, communities at the highest risk of flooding require the most 
extensive, detailed data and analysis, but the same level of data 
collection and analysis may not be necessary to create accurate, useful 
maps for communities with lower flood risks. Defining the level of data 
collection and analysis for different levels of risk are important 
because obtaining and analyzing flood map data is time-consuming and 
expensive, and the more detailed and specific the data, generally the 
greater the effort and costs required to obtain it. By identifying the 
types, quantity, and specificity of the data and analysis needed for 
communities based on their risk, we concluded that FEMA could better 
ensure that data collection and analysis is consistent for all 
communities with similar risk and that it is using its resources 
efficiently while producing maps that are accurate and useful for 
communities at different levels of flood risk. FEMA acknowledged the 
need to develop such standards, but, at the time of our review, had not 
yet developed draft standards or included this task into its map 
modernization implementation plan. In November 2004, FEMA issued its 
Multi-Year Flood Hazard Identification Plan. The plan describes FEMA's 
strategy for addressing our concerns and discusses the varying types of 
data collection and analysis techniques the agency plans to use to 
develop flood hazard data in order to relate the level of study and 
level of risk for each county. 

* Expand outreach and better inform the user community: FEMA's planned 
expanded outreach efforts are intended to increase public awareness and 
obtain community acceptance of the updated flood maps because the 
updated information could potentially identify changes in floodplain 
boundaries and, therefore, affect property owners, including whether or 
not their property's location may require them to purchase federal 
flood insurance. FEMA's intended outcome for these outreach efforts is 
to reduce community vulnerability to natural and man-made hazards and 
increase participation in the flood insurance program. Because FEMA 
does not have the authority to require that affected property owners 
take steps to protect their properties against flood risks or to ensure 
that owners whose properties are in the floodplain purchase flood 
insurance, effective outreach is essential to ultimately achieve these 
benefits. 

* Establish and maintain effective partnerships: FEMA's objective for 
building and maintaining mutually beneficial partnerships is designed 
to facilitate and support the efficient production and effective use of 
maps. FEMA recognizes that local, state, and federal agencies that have 
been working on mapping activities for years, have the resources and 
potential to positively affect the quality and quantity of the data 
collected and improve the way these data are used. In addition, these 
partnerships can enable FEMA to leverage its resources and reduce the 
federal costs of map modernization. FEMA had developed a strategy for 
partnering with these agencies to encourage greater involvement in map 
modernization, including the contribution of resources. However, we 
concluded that the overall effectiveness of the agency's partnering 
efforts was uncertain because FEMA had not yet developed a clear 
strategy for partnering with communities that have few resources, 
limited mapping capability, and little history of flood mapping 
activities. FEMA's Multi-Year Flood Hazard Identification Plan (the 
Plan) does not explicitly address such strategies. For fiscal year 
2004, the Plan notes that, nationwide, dollars leveraged from local, 
non-FEMA sources substantially exceeded the target level of 20 percent, 
with 36 percent of the effort leveraged from other partners. In 4 of 
the 10 FEMA regions the leverage exceeded 40 percent. However, in 3 of 
the 10 FEMA regions the leverage was less than 10 percent. This 
experience, along with a projected 50 percent increase in the total 
cost of the program, supports the need for strategies to address 
disparities and maximize map modernization stakeholders' contributions 
to the program. 

* Achieve effective program management: In March 2004, FEMA awarded a 
performance-based contract to a single contractor to oversee map 
modernization that includes performance measures to gauge the success 
of its efforts. Through a staffing analysis, FEMA had determined that 
it needed 75 staff with specific, identified skills to effectively 
monitor and manage the contract and overall map modernization program. 
As of March 2004, FEMA had hired 1 of the 75 staff, and had developed 
plans to hire or transfer 43 others, but had not yet determined how it 
would acquire the remaining 31 positions. In addition, we found that 
FEMA had not clearly defined performance measures related to whether 
(1) the revised maps meet any established standards for accuracy and 
(2) outreach efforts are successful in increasing the community and 
individual awareness and use of flood maps. In response to our 
recommendation, FEMA's set goals in its November 2004 Multi-Year Flood 
Hazard Identification Plan for key performance indicators. FEMA's four 
indicators are (1) Population with Digital GIS Flood Data Available 
Online, (2) Population with Adopted Maps that Meet Quality Standards, 
(3) Percent of Effort Leveraged; that is, state and local resources 
provided for map modernization as a percentage of FEMA resources 
provided, and (4) Appropriated Funds Sent to Cooperating Technical 
Partners (CTP). To track its progress of map modernization annually, 
FEMA set target percentages for achieving these performance indicators 
in fiscal years 2006 through 2009. 

Map Modernization Intends to Use Advanced Technologies to Produce More 
Accurate and Accessible Digital Flood Maps: 

Through map modernization, FEMA intends to produce more accurate and 
accessible flood maps by using advanced technology to gather accurate 
data and make the resulting information available on the Internet. Many 
of the flood maps in FEMA's inventory do not accurately reflect the 
true flood hazard risks because over time, new development and other 
factors altered watersheds and floodplains faster than the maps could 
be updated. Prior to fiscal year 2004, the $35 million to $50 million 
in annual flood insurance policy fees had been the only source of 
funding for updating flood maps, and according to FEMA, the agency had 
not been able to keep the maps updated with the funds available. As a 
result, at the time of our review, nearly 70 percent of the nation's 
approximately 92,222 flood maps[Footnote 6] were more than 10 years old 
and many contain inaccurate data, according to FEMA. 

Over time, physical conditions in watersheds and floodplains can 
change, and improvements in the techniques for assessing and displaying 
flood risks are made. FEMA plans to use the latest technology, such as 
GIS, to create accurate digital flood maps. GIS technology provides the 
foundation for achieving FEMA's goals of melding different types and 
sources of data to create the new digital flood maps and making the new 
digital flood maps available to a variety of users over the Internet. 
The primary function of GIS is to link multiple digital databases and 
graphically display that information as maps with potentially many 
different types of "layers" of information. When layers of information 
are formatted using the same standards, users can potentially overlay 
various layers of information about any number of specific topics to 
examine how the layers interrelate. Each layer of a GIS map represents 
a particular "theme" or feature, and one layer could be derived from a 
data source completely different from the other layers. For example, 
one theme could represent all the streets in a specified area. Another 
theme could correspond to the topography or elevation data of an area, 
and others could show aerial photography and streams in the same area. 
These themes are all key elements needed to create flood maps that 
accurately depict floodplains and can be used to identify properties in 
these areas. In preparing for full-scale implementation of map 
modernization, FEMA had established standards and graphic 
specifications for digital flood maps created with GIS. 

GIS technology also enables the creation of more accurate and 
accessible maps than would be possible with older mapping methods and 
technology. The majority of FEMA's flood map inventory was produced 
using manual techniques that have inherent accuracy and accessibility 
limitations. For example, in creating traditional paper flood maps, 
field measurements taken by surveyors would have been transferred by 
hand to paper base maps. If the paper base map contained any 
inaccuracies, then the field-survey data could be shown in the wrong 
place on the final flood map. This would then result in floodplain 
boundaries being shown in the wrong place. 

By their nature, paper flood maps have limited accessibility as 
compared with a digital map that can be made available on the Internet. 
The expansion of Internet connectivity in recent years has 
substantially enhanced the potential value of digital maps created with 
GIS because now it is possible to locate and connect data from many 
distinct GIS databases to develop analytical information on almost any 
topic that is associated with physical locations. Digital flood maps 
created according to FEMA's standards are intended to provide users not 
only with the ability to determine the flood zone and base flood 
elevations for a particular location, but also with the ability to 
access other information like road, stream, and public land survey 
data. Communities could use this information for a variety of purposes, 
including decisions on future development and evacuation routes. 

As part of map modernization, FEMA has promoted the use of a variety of 
advanced technologies to improve the accuracy of flood maps. In recent 
years, for example, where it deems it appropriate, FEMA has promoted 
the use of Light Detection and Ranging (LIDAR) remote sensing 
technologies to generate highly detailed, digital elevation data. 

Elevation data are a key component needed to determine flood risk and 
identify floodplain boundaries. According to FEMA, for very flat areas 
where small changes in elevation can have a large impact on where flood 
plain boundaries are drawn, LIDAR can provide the level of detail 
needed to accurately delineate these boundaries. Communities can also 
use detailed, digital elevation data for planning and land development 
purposes. 

FEMA Expects Map Modernization to Increase the Likelihood Maps Will Be 
Used for Risk Management: 

FEMA expects map modernization to increase the likelihood that the more 
accurate and accessible maps will be used for risk management purposes. 
Specifically, FEMA expects the new maps to be used to (1) improve flood 
mitigation, (2) increase flood insurance participation, and (3) improve 
"multi-hazard" mitigation and risk management capabilities. First, FEMA 
expects communities to be able to use these new and revised maps to 
better manage and mitigate flood risk by regulating floodplain 
development through building codes, ordinances, and regulations. 
Second, the new maps also have the potential to help increase flood 
insurance participation because they will more accurately identify 
those properties that are in the floodplain and whose owners would be 
required to purchase flood insurance. Third, the data and 
infrastructure developed by map modernization is also expected to help 
national, state, and local officials mitigate and manage risk from 
multiple hazards, both natural and man-made. Accurate digital maps can 
provide more precise data on such things as the location of hazardous 
material facilities, power plants, railroads, and airports to state and 
national officials for planning development as well as to assess 
internal weaknesses and evacuation routes. 

Map Modernization Is Expected to Improve Flood Mitigation: 

The more accurate and updated flood hazard information produced through 
map modernization is expected to help improve flood mitigation in 
participating communities. The NFIP requires participating communities 
to adopt and enforce building standards based on the floodplain 
boundaries and base flood elevations when maps are updated. For 
example, the lowest floor of structures in new construction must be 
elevated to at least the base flood elevations identified on the maps. 
FEMA's policy is to monitor communities to ensure that they have 
adopted building standards that meet the minimum NFIP criteria and to 
ensure that they are effectively enforcing these standards. If 
communities fail to establish and enforce minimum NFIP flood plain 
building standards, FEMA can suspend availability of federal flood 
insurance. 

Communities also may use updated flood hazard data to take actions to 
mitigate flooding that go beyond adopting the building standards 
required by the NFIP. For example, communities may use the data from 
the maps to identify where to conduct capital improvement projects 
designed to mitigate flooding of structures in the floodplain. In 
addition, FEMA has established a Community Rating System that provides 
discounts on flood insurance premiums for those communities that take 
mitigation actions beyond those required by the NFIP. 

Map Modernization Is Expected to Help Increase Flood Insurance 
Participation: 

Map modernization has the potential to help increase flood insurance 
participation. The accuracy of the new maps should better identify at- 
risk property owners who would be best served by obtaining flood 
insurance whether or not the owners would be required to purchase 
insurance under the NFIP's mandatory purchase requirement. Moreover, 
the digital, GIS-based maps should make flood risk information more 
accessible to a variety of users such as lenders and community 
officials who could conduct targeted outreach to these property owners. 

It is important to note, however, that FEMA, states, and communities do 
not have the authority to ensure that property owners who are subject 
to the mandatory purchase of flood insurance requirement actually 
purchase flood insurance. It is the federally regulated lenders' 
responsibility to ensure that borrowers purchase flood insurance and 
that the insurance policy is maintained throughout the loan's life as 
each new lender servicing the loan becomes aware that the affected 
property is at risk for flooding. Furthermore, owners of properties 
without mortgages or properties with mortgages held by unregulated 
lenders are not required to purchase flood insurance, even if the 
properties are in floodplains. 

Map Modernization Is Expected to Improve Multi-Hazard Mitigation and 
Risk Management Capabilities: 

FEMA expects that the data developed, collected, and distributed 
through map modernization will help national, state, and local 
emergency managers mitigate and manage risk posed by other natural and 
man-made hazards. Accurate digital base maps provide more precise data 
to state and national officials for planning, such as the location of 
hazardous material facilities, power plants, utility distribution 
facilities, and other infrastructure (bridges, sewage treatment plants, 
buildings, and structures). According to FEMA, map modernization will 
also support DHS's overall goal to reduce the nation's vulnerability to 
terrorism by providing GIS data and capabilities to other departmental 
functions. For example, more accurate information on transportation 
systems such as railroads, airports, harbors, ports, and waterways 
should be helpful in assessing internal weaknesses and evacuation 
routes. 

FEMA's Strategy for Map Modernization Shows Promise, but Challenges 
Remain: 

FEMA's strategy for managing map modernization is intended to support 
the achievement of the expected program benefits of improved flood 
mitigation, increased NFIP insurance participation, and improved multi- 
hazard mitigation and risk management capabilities. However, in 
reviewing FEMA's approach to implementing the strategy, we identified 
several challenges that could hamper the agency's efforts. FEMA's 
approach is based on four objectives. Two objectives FEMA hopes to 
achieve through map modernization--building and maintaining a premier 
data collection and delivery system and expanding outreach and better 
informing the user community--have the potential to improve the use of 
flood maps for improved flood mitigation and increased NFIP 
participation, as well as multi-hazard risk management. The other two 
objectives--building and maintaining mutually beneficial partnerships 
and achieving effective program management--are intended to facilitate 
the achievement of the first two objectives and their intended benefits 
efficiently and effectively. 

In Its Efforts to Establish a New Data System, FEMA Had Not Yet 
Established Data Standards for Different Levels of Risk: 

The goal of FEMA's objective to develop a new data system using the 
latest technology is more efficient production, delivery and, thereby, 
the use of flood maps. As discussed previously, FEMA hopes to 
accomplish this by using geographic information systems technology that 
provides the foundation for the production and delivery of more 
accurate digital flood maps and multi-hazard data that is more 
accessible over the Internet. 

In developing the new data system to update flood maps across the 
nation, FEMA's intent is to develop and incorporate flood risk data 
that are of a level of specificity and accuracy commensurate with 
communities' relative flood risks. According to FEMA, there is a direct 
relationship between the types, quantity, and detail of the data and 
analysis used for map development and the costs associated with 
obtaining and analyzing those data. FEMA believes it needs to strike a 
balance between the relative flood risk faced by individual communities 
and the level of analysis and effort needed to develop reliable flood 
hazard data if it is to update the nation's maps efficiently and 
effectively. 

FEMA ranked all 3,146 counties from highest to lowest based on a number 
of factors, including, among other things, population, growth trends, 
housing units, flood insurance policies and claims, repetitive loss 
properties, and flood disasters. On the basis of this ranking, FEMA 
established mapping priorities. However, at the time of our review, 
FEMA had not established standards on the appropriate data and level of 
analysis required to develop maps based on risk level. FEMA had 
historically applied the same minimum standards for all flood maps and 
supporting data.[Footnote 7] FEMA's Guidelines and Specifications for 
Flood Hazard Mapping Partners provided guidance for selecting the level 
of analysis and effort to produce flood hazard data and the guidelines 
had generally been used on a case-by-case basis.[Footnote 8] We found 
that the guidelines do not specify standards to be used for all mapping 
projects within a given risk category and concluded that, without 
establishing standards for different categories of risk, FEMA could not 
ensure that it uses the same level of data collection and analysis 
across all communities within the same risk category. These standards 
could also provide a consistent basis for estimating the costs of 
developing maps in each risk category. At the time of our review, FEMA 
had not yet developed draft standards or incorporated this task into 
its implementation plan. As a result, we recommended that FEMA develop 
and implement data standards that would enable FEMA, its contractor, 
and its state and local partners to identify and use consistent data 
collection and analysis methods for communities with similar risk. 

In November 2004, FEMA issued its Multi-Year Flood Hazard 
Identification Plan. The plan describes FEMA's strategy for updating 
flood maps used for NFIP purposes and discusses the varying types of 
data collection and analysis techniques the agency plans to use to 
develop flood hazard data in order to relate the level of study and 
level of risk for each county. 

FEMA's Objective to Expand Outreach Efforts Recognizes the Agency Must 
Rely on Others to Achieve Map Modernization Benefits: 

FEMA's objective to expand the scope and frequency of its outreach 
efforts is intended to increase community and public acceptance of 
revised maps and use of those maps. Historically, FEMA has only 
contacted communities when initiating remapping and again when 
preliminary maps are completed. These expanded outreach efforts reflect 
FEMA's understanding that it is dependent on others to achieve the 
benefits of map modernization. For example, under the structure of the 
NFIP, FEMA is dependent on communities to adopt and enforce FEMA's 
minimum building standards and on mortgage lenders to ensure compliance 
with mandatory flood insurance purchase requirements. To expand the 
scope of its outreach efforts, FEMA plans to involve a wide variety of 
community participants--e.g., mayors, emergency managers, lenders, 
property owners, insurance agents, and developers--in the mapping 
process. To expand the frequency of outreach, FEMA intends to increase 
community involvement, awareness, and participation throughout the 
entire flood mapping process. Through a continual education process, 
FEMA's goal is to inform property owners and others potentially 
affected by remapping efforts of steps they can take to mitigate the 
risk of flooding, the types of damage and costs caused by flooding, and 
the benefits of flood insurance. 

According to FEMA, if a community is involved in and understands the 
map modernization process, the community is more likely to accept and 
trust the accuracy of the final, revised maps and is more likely to use 
the maps' hazard data to mitigate natural and man-made disasters. 
Conversely, if affected property owners do not understand why their 
communities are being mapped (or remapped) or why their property is now 
in a flood zone, the unexpected additional expense of new or increased 
flood insurance premiums can form the basis of significant community 
opposition to map modernization activities and lead to formal appeals, 
litigation, and delays in implementing map changes. 

FEMA's expanded outreach efforts are intended to educate the public of 
the potential flood risk in communities and to encourage them to take 
action. Communities that participate in the NFIP are required to 
establish floodplain management ordinances that require new and 
substantially improved structures in newly designated floodplains to 
meet NFIP building standards. However, if a property was not located in 
the floodplain in the old map but is in the floodplain in the new 
revised map, NFIP floodplain management regulations do not require 
those owners to implement mitigation measures unless they make 
substantial improvements to the structure.[Footnote 9] FEMA cannot 
compel affected property owners to take steps to protect their 
properties against flood risks or to purchase flood insurance. Under 
current notification requirements, federally regulated lenders, not 
FEMA, serve as the primary channel for notifying property owners whose 
mortgaged properties are subject to flood insurance requirements. When 
property owners seek new financing, through purchase or refinancing, 
federally regulated mortgage lenders are required to determine if the 
property is in the floodplain and, if so, require the purchase of flood 
insurance. Lenders are not required to monitor map changes or to notify 
property owners with existing mortgages whose properties are identified 
in a floodplain by remapping if they are not aware of the change in 
status.[Footnote 10]

Nonetheless, if federally regulated lenders become aware of flood map 
changes that affect properties for which they hold mortgages through 
FEMA notifications or flood zone determination companies,[Footnote 11] 
then they must notify the property owner and require the purchase of 
flood insurance. The information that must be provided to property 
owners is limited to notifying property owners that their structure is 
in a floodplain, providing a definition of a flood plain, and requiring 
the purchase of flood insurance if they live in a participating NFIP 
community. As a result, FEMA's outreach efforts are important for 
supplementing the formal requirements for notifying communities and 
property owners of map changes. 

FEMA's Strategy for Partnering with States and Local Communities Does 
Not Include Communities with Few Resources to Assist in Flood Mapping: 

FEMA's objective for building and maintaining mutually beneficial 
partnerships is intended to facilitate and support the efficient 
production and effective use of flood maps. According to FEMA, local, 
state, and federal partners that have invested resources and assisted 
in managing mapping activities have the potential to positively affect 
the detail, accuracy, and quantity of the data collected and improve 
how these data are used. As part of their strategy for partnering, FEMA 
provides guidance to the states on how to develop "business plans" that 
document planned efforts to develop states' and communities' capability 
and capacity to oversee the collection, analysis, and implementation of 
flood data in their state and community and to justify funding for 
these efforts. According to FEMA, 38 states had begun drafting such 
plans. FEMA intends to use these state business plans to help 
prioritize its continuing efforts to develop map modernization 
partners. 

Through its CTP program, FEMA has developed partnerships with a variety 
of states and communities that have developed their own data and 
provided their own funds to help update local flood maps. Since 2000, 
FEMA has leveraged millions of dollars in funding from 171 partners 
(states and local communities) for producing maps through its CTP 
program. For example, from fiscal years 2000 to 2002, FEMA used $70 
million of its federal map modernization funding along with state and 
local funds to develop what FEMA has estimated to be more than $155 
million worth of new mapping data. According to FEMA, partnering has 
other benefits as well. For example, in the long-term, those states and 
communities with whom FEMA has established partnerships may be more 
likely to accept final map changes, expand their capabilities, and 
assume greater responsibility for periodically developing and 
incorporating updated flood data, resulting in cost savings to FEMA. 

Some states and communities with few resources and technical capacities 
or little history of flood mapping activities are likely to pose a 
challenge to FEMA's ability to fund and implement mapping activities. 
For example, we talked with flood management officials in several 
smaller communities in Montgomery County, Texas; Santa Cruz County, 
Arizona; and Larkspur, Colorado. These officials said that their 
communities lacked either the funding needed to develop flood data, the 
technological capability to develop digital flood data and use 
geospatial information systems, or, in some cases, the community 
support needed to conduct mapping activities. One approach for 
obtaining additional resources, capabilities, and community support 
would be for FEMA to facilitate coordination with other agencies within 
the state that have a stake in, or could benefit from, mapping 
activities. For example, state departments of transportation can 
benefit from information in FEMA's geospatial information system, such 
as elevation data, in planning and building state roads and bridges. 
North Carolina was able to get its state transportation department to 
help fund the development of elevation data used for flood maps. At the 
time of our review, FEMA had not yet developed a strategy for how to 
partner with communities that do not have the resources, capabilities, 
or motivation to initiate and sustain mapping activities. Such a 
strategy could focus on how to assist these potential partners in 
garnering community resources and developing technological 
capabilities, how to coordinate with other agencies in their state, and 
how to integrate these efforts with FEMA's community outreach efforts 
to gain community support for mapping activities. As a result, we 
recommended that FEMA develop and implement strategies for partnering 
with state and local entities with varying levels of capabilities and 
resources. FEMA's Plan does not explicitly address such strategies. For 
fiscal year 2004, the Plan notes that, nationwide, dollars leveraged 
from local, non-FEMA sources substantially exceeded the target level of 
20 percent, with 36 percent of the effort leveraged from other 
partners. In 4 of the 10 FEMA regions the leverage exceeded 40 percent. 
However, in 3 of the 10 FEMA regions the leverage was less than 10 
percent. This experience, along with a projected 50 percent increase in 
the total cost of the program, supports the need for strategies to 
address disparities and maximize map modernization stakeholders' 
contributions to the program. 

Program Management Contract Is Performance-Based, but FEMA May Have 
Difficulty Overseeing the Contract and Measuring Achievement of Program 
Objectives: 

In March 2004, FEMA awarded a performance-based contract to obtain 
assistance from a nationwide mapping contractor to manage tasks 
associated with the significant expansion of the map modernization 
program. Unlike many traditional government service contracts, which 
emphasize inputs rather than outcomes, a performance-based contracting 
approach gives the contractor the flexibility to determine how best to 
achieve the outcomes and links payment to the contractor's ability to 
achieve these outcomes--an approach supported by our past work in 
federal contracting. Overseeing these types of contracts requires 
agency staff with the knowledge, skills, and abilities to monitor the 
contractor's efforts using performance measures that accurately measure 
agreed-upon outcomes. 

We concluded that FEMA might be limited in its ability to effectively 
manage the contract, as well as the significant expansion of tasks 
associated with a five-fold increase in funding and related mapping 
activities that will continue to be performed by agency staff. These 
tasks include managing grants for many new mapping partners and 
administering contracts with independent firms to develop and process a 
significantly larger quantity of flood data to support local efforts. A 
staffing needs assessment completed by FEMA in December 2003 identifies 
a need for an additional 75 staff with additional skills, including 
contracting and program management capabilities. In appropriating 
fiscal year 2004 map modernization funds, Congress included a provision 
that would allow FEMA to use up to 3 percent, or $6 million, for 
administrative purposes. As of March 2004, FEMA had filled 1 of the 75 
positions by reallocating existing resources. At the time of our review 
FEMA planned to fill another 33 positions using the administrative 
funding identified in the fiscal year 2004 budget. In addition, FEMA 
also planned to fill an additional 10 positions by moving staff from 
other FEMA departments or filling vacancies. However, at the time of 
our review, FEMA had not yet established a plan for filling the 
remaining 31 headquarters and regional positions. As a result, we 
recommended that FEMA ensure that it has the staff capacity to 
effectively implement the nationwide mapping contract and the overall 
map modernization program. 

One element of effective program management is establishing performance 
measures to determine how well FEMA is achieving its map modernization 
program objectives. FEMA had established performance measures for all 
four of its program objectives. However, we concluded that FEMA's 
measures for two of those objectives that directly support the use of 
flood maps for risk management--to develop a premier data system and to 
expand and better inform the user community were not clearly defined or 
fully developed. FEMA's principal measure for developing and 
maintaining a premier data collection and delivery system is the 
percent of the national population with community-adopted, GIS data- 
based flood maps. However, this measure does not indicate whether the 
maps themselves meet any FEMA-established standards for accuracy 
(because FEMA had not yet defined the minimum level of data collection 
and analysis for communities with similar risk). 

To measure the progress and success of expanding and better informing 
the user community, FEMA established performance measures related to 
the percent increase in communities' awareness and use of new maps. 
FEMA plans to use surveys as the primary means of measuring increased 
community awareness and use of the new maps. However, FEMA had not yet 
fully developed an operational definition of how it plans to measure 
"awareness" or "use," for example, that reflect mitigation steps taken 
or the purchase of flood insurance. Because the link between revising 
maps and the use of maps in terms of increased NFIP participation is 
not direct, we recognized that it may be a challenge to develop a 
performance measure that accurately reflects the impact on NFIP 
participation rates of efforts to expand and improve outreach. 
Nonetheless, without developing such a measure (or measures), we 
concluded that FEMA would be less able to ensure that its map 
modernization program will have resulted in one of FEMA's primary 
intended benefits. As a result, we recommended that FEMA develop and 
implement useful performance measures that define FEMA' s progress in 
increasing stakeholders' awareness and use of the new maps, including 
improved mitigation efforts and increased participation rates in 
purchasing flood insurance. 

In response to our recommendation, FEMA's set goals in its November 
2004 Multi-year Flood Hazard Identification Plan to improve public 
safety through the availability of reliable flood risk data. 
Specifically, FEMA plans to increase the safety for at least 85 percent 
of the U.S. population through availability of accurate flood risk data 
in GIS format. To achieve this goal, FEMA has set targets for key 
performance indicators (KPI) through fiscal year 2009 (production is 
scheduled for completion in fiscal year 2010). FEMA's four KPIs are (1) 
Population with Digital GIS Flood Data Available Online, (2) Population 
with Adopted Maps that Meet Quality Standards, (3) Percent of Effort 
Leveraged; that is, state and local resources provided for map 
modernization as a percentage of FEMA resources provided, and (4) 
Appropriated Funds Sent to CTPs. To track its progress of map 
modernization annually, FEMA set target percentages for achieving these 
performance indicators in fiscal years 2006 through 2009. 

Mr. Chairman and Members of the Committee, this concludes my prepared 
statement. I would be pleased to answer any questions you and the 
Committee Members may have. 

Contact and Staff Acknowledgments: 

For further information about this statement, please contact William O. 
Jenkins, Jr. Director, Homeland Security and Justice Issues on (202) 
512-8777 or jenkinswo@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. GAO staff who made major contributors to this 
testimony included Grace Coleman, Christopher Keisling, Raul Quintero, 
and John Vocino. 

FOOTNOTES

[1] Prior to March 2003, FEMA was an independent agency whose Federal 
Insurance and Mitigation Administration was responsible for managing 
the flood insurance program. The Homeland Security Act of 2002, P.L. 
107-296 (Nov. 25, 2002), transferred FEMA and all its responsibilities 
to the Emergency Preparedness and Response Directorate within the new 
Department of Homeland Security. This transfer was effective March 1, 
2003. Currently, the Mitigation Division within FEMA is responsible for 
the flood insurance program, including flood map modernization. 

[2] GAO, Flood Map Modernization: Program Strategy Shows Promise, but 
Challenges Remain, GAO-04-417, (Washington, D.C.: March 31, 2004)

[3] Data are from the U.S. Army Corps of Engineers in cooperation with 
the National Weather Service. 

[4] Mitigation is defined by the Federal Emergency Management Agency as 
sustained action that reduces or eliminates long-term risk to people 
and property from hazards and their effects. 

[5] See 42 U.S.C. 4001 et seq. 

[6] The 92,222 flood maps represent nearly 20,000 communities. 

[7] For example, FEMA implemented digital base map standards in 1998 
and LIDAR standards in 2000. 

[8] These guidelines describe detailed methods of analysis used for 
high-risk areas and less detailed methods used for low-risk areas. 

[9] If a community determines that the cost of improvements to a home 
or business equals or exceeds 50 percent of the market value of the 
building, the building is considered a "substantial improvement" and 
must meet the NFIP's minimum requirements. 

[10] In making loans, federally regulated lenders are required to 
ensure that property owners purchase flood insurance if their mortgages 
are secured by a structure located in a floodplain. Lenders are also 
required to check the flood hazard status of a property when triggered 
by statutory tripwires, such as loan renewal or extension. 

[11] Many lenders use flood zone determination companies to determine 
whether properties require flood insurance as a result of loan 
origination, loan assumption, or map changes. These companies use FEMA 
flood maps and other data to ascertain if properties are situated in 
flood zones.